Ezeamama v. In Re: The Estate of Catherine Ezeamama Chibugo
The probate court determined that real property titled in a single-member LLC wholly owned by the decedent became an estate asset because the LLC dissolved immediately upon the sole member's death. The Third District reversed, holding that assets of a single-member LLC are not estate assets and that a member's death causes dissociation, not automatic dissolution; dissolution occurs only after 90 consecutive days with no members, followed by filing articles of dissolution.
Key facts
- Decedent Catherine Ezeamama Chibugo was the sole member of a single-member LLC that held real property; upon her death, the probate court determined the LLC's real property became an estate asset because the LLC automatically dissolved.
- The probate court's order treating the LLC's underlying assets as estate property was appealed by the estate representatives or interested parties.
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Why it matters
This decision squarely applies corporate-separateness principles to single-member LLCs in the probate context, giving practitioners a clean citation that a decedent's 100% membership interest — not the LLC's underlying… — full analysis with a trial
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