Grant v. Kunke

In a probate dispute over caregiving claims against a decedent's estate, the Second District affirmed the probate court's determination that the caregiving daughter was a reasonably ascertainable creditor who, after an objection was filed, had to pursue the merits of her claim in an independent civil action (and whose claim was barred when she failed to act within the 45 days allowed). The court reversed as to her husband, holding the probate court abused its discretion in finding him not to be a reasonably ascertainable creditor where the personal representative had actual knowledge of the caregiving arrangement and had encouraged the couple to document expenses and file claims.

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