Ranking v. Ranking Estate

Ranking v. Ranking Estate

Because the appellant elected to take under the Family Law Act rather than under the will, he is entitled to the benefits of that election but must accept its burdens; applying the Act's equalization scheme accordingly yields the appellant's entitlement and requires dismissal of the appeal.

Source-derived case information.

Citation
2010 ONCA 315
Parties
Appellant/applicant: Gerald N. Ranking, by his Litigation Guardian Gerald L.R. Ranking; Respondent: David Battah, in his capacity as the Executor and Trustee of the Estate of Rosella (Margo) Ranking, Deceased
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
3 May 2010
Procedural Posture
Civil / Appeal From Superior Court of Justice
Outcome
Appeal dismissed
Legal Topics
Election Under Family Law Act Vs Will, Equalization Under Family Law Act, Estate Distribution, Costs and Interest
Source Language
en
Family Law Estate Law Civil Procedure Election Under Family Law Act Vs Will Equalization Under Family Law Act Estate Distribution Costs and Interest

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Parties

Gerald N. Ranking, by his Litigation Guardian Gerald L.R. Ranking

Appellant/applicant

David Battah, in his capacity as the Executor and Trustee of the Estate of Rosella (Margo) Ranking, Deceased

Respondent

Procedural Posture

Civil / Appeal From Superior Court of Justice

  1. 1 Whether the appellant's election to take under the Family Law Act bars reliance on the will and imposes associated burdens
  2. 2 Whether the Superior Court's interpretation of the Family Law Act equalization scheme was correct
  3. 3 Appropriate quantum payable from the estate and costs

Ratio Decidendi

Because the appellant elected to take under the Family Law Act rather than under the will, he is entitled to the benefits of that election but must accept its burdens; applying the Act's equalization scheme accordingly yields the appellant's entitlement and requires dismissal of the appeal.

Court Disposition

Appeal dismissed

Orders

  • Appellant to receive $122,437.08 from the estate together with interest pursuant to the Courts of Justice Act
  • Costs to respondent fixed at $8,500 inclusive of disbursements and G.S.T.