A successor trustee and attorney-in-fact cannot delete charitable beneficiaries designated by an incapacitated settlor of the trust to name himself as beneficiary when the settlor dies, an appellate court in the District of Columbia has ruled. It has affirmed a trial court summary judgment and agreed that the trustee/attorney-in-fact did not act in accordance with the settlor’s reasonable expectations. John Michael Garner executed several estate-planning documents, including a trust and a durable power of attorney. The trust named himself as beneficiary during his lifetime and named four charities as beneficiaries after his death. It named his nephew Patrick Garner as successor trustee in...