In the preparation of a comprehensive estate plan for a client, an attorney must consider the size of the estate, the manner in which assets are titled, transfer and income tax issues, and family dynamics.  In light of the recent United States Supreme Court decision in Clark v. Rameker[1], ("Clark") there is now one more area of concern.

Before Clark

On April 29, 2014, the Arizona Court of Appeals, Division 1, issued a ruling granting relief in favor of a receiver, and thereby strengthening a receiver's security by limiting his responsibilities and liabilities as follows: