The California Court of Appeal ruled on September 2, 2026 that a trust’s equalisation clause does not permit deductions of rental income from the Sandford siblings’ inheritance shares. The decision unravels a controversial Orange County trial court ruling that had treated $537,930 of Mark Sandford’s rent and $601,560 from the Orange Park property as early distributions. By striking down those deductions, the appellate court restores the brothers’ full entitlement to the trust’s assets.
The Sandford family established a 1998 trust after Dean Sandford died intestate in 1988. Jean Sandford, the sole trustee, named her daughters Debra, Pamela and Linda as successors, later adding sons Michael and Mark in 2000. The trust’s equalisation clause was designed to offset unpaid loans and unequal gifts, but its scope had been stretched by the trial court to include rental and sale proceeds.
In 2018, Debra and Linda petitioned for a full accounting, removal of Michael and Mark as trustees, and an audit of assets held between 2009 and 2020. The Orange County Superior Court, after 22 days of testimony, ruled that the brothers were untrustworthy, removed them, and ordered deductions of $145,620 each from rental income between 2002 and 2020. It also treated the $829,000 net proceeds from the 2008 sale of the Wilken Way fourplex as an early distribution.
The appellate court held that the equalisation clause’s ordinary meaning covers only loans and gifts, not every financial benefit a beneficiary may receive. It cited the statute of limitations to bar claims arising from alleged misconduct in the property transactions, noting that the trial court had already found no fraud. The court emphasized that the clause cannot be used to strip inheritance shares of proceeds that were not advances against a debt.
The ruling means Mark and Michael will not have rental income subtracted from their shares, while the $60,000 loan to Michael remains subject to deduction. The case now returns to the Orange County Superior Court for the implementation of the revised share calculations, and the siblings are expected to file amended petitions before the next hearing in November. Meanwhile, Linda, who managed Mark’s rental accounts, says the decision will finally bring closure to a decade‑long family feud.