Three cheers for Justice Donohue! Clearly, she has heard of this newsletter and wants to make our lives easier. The Justice perfectly summarized the Pennsylvania Supreme Court’s holding from In re Passarelli Family Trust in the opinion’s first paragraph, making life oh so much easier for yours truly. Justice Donahue wrote that the Supreme Court was “asked to determine the burden of proof for a settlor of an irrevocable trust in order to void the trust on the grounds of fraudulent inducement in the creation of the trust. We hold that a settlor averring fraud in the inducement of an irrevocable trust must prove by clear and convincing evidence the elements of common law fraud. In doing so, we reject the analysis set forth in In re Estate of Glover, 669 A.2d 1011 (Pa. Super. 1996), because it represents an inaccurate statement of the elements required to establish fraud in the inducement.”