IN RE: the Supervised ESTATE OF Clair D. BOYD; Laura D. Boyd (2026)

MEMORANDUM DECISION

Case Summary

[1] Laura D. Boyd (“Boyd”), pro se, appeals the trial court's dismissal of her Indiana Trial Rule 60(B) motion for relief from judgment. Boyd raises one issue, namely, whether the court erred when it dismissed her motion. We affirm.

Facts and Procedural History

[2] Clair Boyd (“Clair”) had five children: Scott, Vincent, Mark, Ryan, and Boyd. On August 28, 1992, Clair executed a trust agreement, and he subsequently executed an amendment to the trust on June 17, 2021. Clair died on June 20, 2022. Scott and Boyd were named co-successor trustees of the trust. Scott was appointed the personal representative of Clair's estate. Following Clair's death, disputes arose among Clair's children. Accordingly, Scott filed a petition to docket the trust, which the court granted in September.

[3] On October 9, 2023, the five children entered into a settlement agreement. Pursuant to that agreement, Boyd was granted ownership of a home, ten thousand dollars, and title to a vehicle. In addition, the parties agreed that Boyd “shall no longer be a Trustee or a beneficiary of the Estate or Trust and shall no longer be entitled to notice of proceedings.” Appellant's App. Vol. 2 at 24. The court approved the settlement agreement on October 23. On November 7, 2024, Scott filed a motion to close the estate as insolvent. The court granted that motion on November 20.

[4] On February 20, 2026, Boyd filed a motion for relief from the court's October 23 order approving the settlement agreement pursuant to Indiana Trial Rule 60(B)(8). Boyd alleged that, prior to the execution of the settlement agreement, she did not receive copies of documentation regarding certain fees that the trust had paid. Thus, she maintains that “material financial information ․ was not disclosed,” which resulted in “procedural unfairness.” Id. at 54. As a result, Boyd asked the court to vacate the settlement agreement. The court rejected Boyd's filing, noting that “[a]ll issues in this matter have been decided upon” and that the “matter was closed” as of November 20, 2024. Id. at 16. This appeal ensued.

Discussion and Decision

[5] We first note that Boyd proceeds pro se. “It is well settled that pro se litigants are held to the same legal standards as licensed attorneys. This means that pro se litigants are bound to follow the established rules of procedure and must be prepared to accept the consequences of their failure to do so.” Basic v. Amouri, 58 N.E.3d 980, 983-84 (Ind. Ct. App. 2016) (internal citation omitted). “These consequences include waiver for failure to present cogent argument on appeal.” Id. at 984.

[6] Further, the remaining beneficiaries have not filed an appellees’ brief. When an appellee does not file a brief, our Court will not undertake the burden of developing arguments on that party's behalf. Thurman v. Thurman, 777 N.E.2d 41, 42 (Ind. Ct. App. 2002). Rather, we apply “a less stringent standard of review” and may reverse the trial court if the appellant establishes prima facie error. Id. Prima facie “means at first sight, on first appearance, or on the face of it.” Id.

[7] On appeal, Boyd alleges that the court erred when it rejected her Trial Rule 60(B) motion. Generally, a grant or denial of equitable relief under Indiana Trial Rule 60 is within the discretion of the trial court and is reviewed for an abuse of that discretion. Baker v. Baker, 50 N.E.3d 401, 403 (Ind. Ct. App. 2016). “However, if a trial court's ruling is strictly based upon a paper record, we will review the ruling de novo because we are in as good a position as the trial court to determine the force and effect of the evidence.” Jahangirizadeh v. Pazouki, 27 N.E.3d 1178, 1181 (Ind. Ct. App. 2015) (citing In re Adoption of C.B.M., 992 N.E.2d 687, 691 (Ind. 2013)). The trial court here ruled solely upon a paper record, and so our review is de novo.

[8] Boyd specifically alleged that the court erred when it dismissed her motion based on its determination that the estate had been closed. Boyd contends that the court “[did] not address the specific grounds” presented in her motion and, as a result, the court did not give “meaningful[ ] consideration” to it. Appellant's Br. at 9.

[9] However, it is well settled that an appellant's argument “must contain the contentions of the appellant on the issues presented, supported by cogent reasoning. Each contention must be supported by citations to the authorities [and] statutes relied on[.]” Ind. Appellate Rule 46(A)(8)(a). Here, Boyd has not directed us to any relevant authority to support her argument.

[10] Boyd entered into the settlement agreement on October 9, 2023, and she makes no argument that she did not do so willingly. The court approved that agreement on October 23. Over one year later, on November 20, 2024, the court closed the estate as insolvent, an order which Boyd does not challenge on appeal. It was not until February 2026, almost two and one-half years after the court approved the settlement agreement and almost one and one-half years after the court closed the estate, that Boyd filed her motion for relief from judgment related to the settlement agreement. But Boyd has not directed us to any authority to show that a trial court can reopen a closed estate for the sole purpose of considering the validity of a settlement agreement entered years prior. Because Boyd does not support her contentions with citations to any relevant authority, she has waived the issue for our review. We therefore affirm the trial court.

[11] Affirmed.

Bailey, Judge.

Brown, J., and Weissmann, J., concur.