Missouri Court of Appeals, Eastern District / Feb 25, 2025
First Community Credit Union v. Samuel Rowley, Sheryl A. Rowley, Appellants, and Archdiocese of St. Louis, Respondent.
Samuel and Sheryl Rowley appealed a summary judgment ruling that a durable power of attorney (DPOA) did not authorize them to designate themselves as payable-on-death (POD) beneficiaries of Thomas L. Nicastro's financial accounts. Nicastro had previously designated the Archdiocese of St. Louis as the sole beneficiary. The appellate court affirmed the trial court's judgment, strictly construing the DPOA and finding that its language did not explicitly authorize the Rowleys to engage in self-dealing by naming themselves as beneficiaries.