RAYMOND LOUBIER IRREVOCABLE TRUST, A. v. LOUBIER,, 858 F.3d 719 (2d Cir. 2017)
. . . Florida Statute § 736.1014, entitled "Limitations on actions against certain trusts,” is not to the contrary . . . After identifying certain limitations, see id. § 736.1014(1), the statute states: "[t]his section does . . . a beneficiary of the trust that is not dependent on the individual liability of the settlor,” id. § 736.1014 . . . But nothing in § 736.1014 indicates that in a direct action against the trust, the trust itself can be . . . Indeed, Florida’s express incorporation of the law of trusts resolves any ambiguity in § 736.1014 in . . .
