In re Estate of Frain

Illinois Appellate Court
Civil Court
Trusts and Estates
Citation
Case Number: 
2025 IL App (2d) 240780
Decision Date: 
Monday, December 29, 2025
District: 
2d Dist.
Division/County: 
Kane Co.
Holding: 
Affirmed.
Justice: 
JORGENSEN

Petitioner, the next-of-kin and independent administrator of a deceased individual, appealed after the trial court denied the petitioner’s motion for turnover of funds in a bank checking account. The trial court denied the motion on the basis that there was a joint account holder with a right of survivorship in the account. The appellate court affirmed, finding that that the trial court did not err where the evidence, including the bank account signature card, reasonably showed that a joint tenancy with survivorship rights was created. (KENNEDY and MULLEN, concurring)