P. 12(f). An alert FrontBurnian gave me a heads up that the Fifth Circuit Court of Appeals issued a decision on Tuesday that looks like it might put a period at the end of that saga. The appellate court upheld the terms of the lower courts order prohibiting Hill III from contesting Hill Jr.s will in any matter, in any court, in any future world. personal injury; Boolean (richard or dick) and cheney . They bought a $9 million dollar estate in swanky Buckhead (think Highland Park on Strait Lane in Dallas), closed on it in July. 999 at 8-9, 8.a and at 20-22, 9.a. Albert Galatyn Hill Jr was born c. 1945. According to Plaintiffs: The Hill Jr. YouTube Encyclopedic. They also assert, because this action arises after May 14, 2010 [the date of the GSA], arises out of the GSA, and involves implementation and enforcement of the GSA and the Final Judgment, it is properly and necessarily brought here. Id. Plaintiffs contend that because Defendants' respective motions improperly make factual assertions that exist outside the pleadings and rely on matters outside the pleadings, the court must convert their motions to dismiss into motions for summary judgment. The estate of albert galatyn hill, jr., through its independent executor margaret keliher, the estate of albert galatyn hill, jr., through its independent . Thus, the court denies Plaintiffs' request to convert the pending Rule 12(b)(1) motions into summary judgment motions. Back on November 8, 2007, Albert G. Hill III sued his father, his sisters, his aunts, and Tom Hunt over the management of Hunt Petroleum and the familys trusts. 2012) (consolidated appeal). Yet, over the next four years, our court weighed in on the settlement' four times. On CandysDirt, I told you about Al and Erin Hill, that's Al Three, who recently moved their family to Atlanta. Further, it is well-established and clearly proper in deciding a 12(b)(6) motion [that a court may] take judicial notice of matters of public record. Trusts due to the Waiver of Standing Clause: In November 2018, the parties filed competing summary judgment motions in Probate Court No. 2, Dallas County, Texas (the Estate Action), seeking to admit the Will to probate, and to appoint an independent executor. of Pardons & Parole, 114 Fed.Appx. 28. Plaintiffs take issue with Defendants' labelling Hill III as a vexatious litigant and accuse Defendants of seeking to avoid the Court's consideration of the specific claims in the Complaint. Id. 330, 331 (5th Cir. Dist., 81 F.3d 1395, 1401 (5th Cir. hidden hills gated community homes for sale Location ron cheats on hermione with lavender fanfiction dramione completed Kolkata (City Center 1) anne arundel county inspections and permits Saltlake Sector 5 (Megatherm/Pantaloon Building) no operations defined in spec swagger net core Saltlake Sector 5 (Webel More) The terms of the Trust Instrument for the MHTE are the same as those of the HHTE except for the designation of, and reference to, the primary beneficiary of each trust. On May 29, 2018, Washburne and Summers filed a motion in the 2020 Action seeking to enjoin Hill III from (1) contesting the Will, (2) challenging the disposition of Hill Jr.'s property in violation of the No. Lyda Hill's Reply 6, Doc. 2012) (describing genesis of the GSA). The Judges overseeing this case are WARREN, INGRID and MONROE, LINCOLN. Things got ugly and complicated as family conflicts are wont to do. Under such circumstances, as the court recognized, for Hill III to acquire the status of a current beneficiary of the Hill Jr. They do not address statutory or prudential standing. ALBERT G. HILL, III and ERIN NANCE HILL, Plaintiffs, v. THE ESTATE OF ALBERT G. HILL JR.; MARGARET KELIHER; TYREE B. MILLER; LYDA HILL; HEATHER HILL WASHBURNE; ELISA HILL SUMMERS; CHESTER J. DONNALLY, JR.; THE ESTATE OF IVAN IRWIN JR.; CAROL E. ERWIN; and THOMAS P. TATHAM, Defendants. Co. v. City of Mont Belvieu, Tex., 611 F.3d 289, 298 (5th Cir. [S]ubject-matter jurisdiction cannot be created by waiver or consent. Howery v. Allstate Ins. Strike 3, Doc. The provision of Rule 15(a)(2) of the Federal Rules of Civil Procedure that states [t]he court should freely give leave when justice so requires is not without limitation. Lyda Hill opposes Plaintiffs' Motion to Strike and, in her reply brief, she argues: Lyda Hill's Reply 2, Doc. Collins, 224 F.3d at 498-99. All Rights Reserved. Defendants and Lyda Hill each incorporated the other's briefing by reference, the court will consider the motions in tandem. 999 at 43, 45. (quoting Venture Assocs. PR-17-04117-2, Probate Court No. Dallas Petroleum Club Will Move to Hunt Building in January 2023. 1996). Albert Galatyn Hill, Sr. Children: 3, including Lyda Hill: Parent(s) H. L. Hunt and Lyda Bunker: Margaret Hunt Hill (1915-2007) was an American heiress and philanthropist. 2005). Because the Hill Jr. 31; Lyda Hill's Reply 2-3, Doc. Steel Co. v. Citizens for Better Environment, 523 U.S. 83, 103 (1998). Date Event Type Description Document; 03/21/2017: Reply brief filed: State [ PDF/68 KB ] State Reply Brief [ PDF/85 KB ] Notice: 02/15/2017: 999 at 12-13, 8.f.i and 8.f.ii; Doc. As such, Rule 12(f) does not apply. 26). Likewise, Erin Hill favored the asset protection trust alternative alone rather than coupling that approach with the purchase of a life insurance policy with their children as beneficiaries, objecting that Hill III essentially would lose his independent appointment power and he would have to pay to assure that loss, making him the only trust beneficiary paying for the right to forgo a power. As part of the Final Judgment, the court, incorporating the No. Long v. GSD&M Idea City, LLC, 798 F.3d 265, 274 (5th Cir. The [f]actual allegations of [a complaint] must be enough to raise a right to relief above the speculative level . when a narcissist wants you back albert galatyn hill iii. 2015), the Fifth Circuit stated, [W]e have not hesitated to apply judicial estoppel to dismiss claims under Rules 12(b)(6) or 12(c) while affirming dismissal of claims based on judicial estoppel. Reply 10-11, Doc. 750 North St.Paul St. At that point, Hill III agreed not to contest the last will and testament of his father, Albert Hill Jr., in return for a nine-figure payment. Copyright 2023, D Magazine Partners, Inc. We use cookies to ensure that we give you the best experience on our website. Reply 10, Doc. Often described as "America's Swiss Founding Father ", [3] [4] he was a leading figure in the early years of the United States, helping shape the new republic's financial system and foreign policy. A claim meets the plausibility test when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Hill III appealed the Final Judgment challenging, among other things, the addition of provisions that were not part of the GSA. ' Id. See 2020 Action, Doc. Before turning to the pending motions to dismiss, the court must address Plaintiffs' Motion to Strike and their associated request that the court convert the pending motions to dismiss into motions for summary judgment. 2004). 2015, no pet.) Katherine Jane Preisinger. When a plaintiff raises an argument for the first time in response to a dispositive motion, the court may consider those claims and arguments as a motion to amend under Federal Rule of Civil Procedure 15(a). 1-2 at 10-11, Art. See generally Hill v. Schilling, 495 Fed.Appx. 2007); Martin K. Eby Constr. See generally Pls.' Defendants and Lyda Hill for lack of subject matter jurisdiction, the court will dismiss their claims pursuant to Federal Rule of Civil Procedure 12(b)(6), as Plaintiffs are estopped under the doctrine of quasi-estoppel (or estoppel by contract) from asserting their claims as set forth in the Complaint. A. In her reply brief, Lyda Hill notes that Plaintiffs mischaracterize a Probate Court order described in her motion. Contest Clause, and (3) violating the GSA and the Final Judgment by asserting claims concerning the Hill Jr. $266.00, Financial info for MILLER, TYREE B. : Transaction Assessment; ; $266.00, Financial: MILLER, TYREE B. ; Total Financial Assessment $590.00 ; Total Payments and Credits $590.00, APPLICATION; Comment: APPLICATION FOR PROBATE OF WILL AND ISSUANCE OF LETTERS TESTAMENTARY. The elements of judicial estoppel are satisfied here: (1) Hill III and Erin previously admitted that the trust beneficiaries have a power of appointment when it suited Plaintiffs' interests to avoid purchasing a life insurance policy (see supra); (2) Judge O'Connor relied on their prior position in not requiring the purchase of such a policy (see 2020 Action, Doc. Kitty Hawk Aircargo, Inc. v. Chao, 418 F.3d 453, 460 (5th Cir. 26 (original emphasis). For the reasons that follow, the court will deny Plaintiffs' request. Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! PR-08-830-2 (the HHTE Probate Suit), that in his Will, Hassie Hunt exercised his general power of appointment under the HHTE to an on behalf of the lineal descendants of [his] sister, Margaret Hunt Hill, per stirpes. Lyda Hill's App., Doc. Albert Galatyn Hill found inU.S., Social Security Applications and Claims Index, 1936-2007 Albert Galatyn Hill found inU.S., Find A Grave Index, 1600s-Current Albert Galatyn Hill found in1940 United States Federal Census Albert Galatyn Hill found in1920 United States Federal Census View more historical records forAlbert Galatyn Hill Spivey, 197 F.3d at 774. Hill III brought a lawsuit in Texas state court in his individual capacity Strike 1, Doc. Quasi-estoppel forbids a party from accepting the benefits of a transaction and then subsequently taking an inconsistent position to avoid corresponding obligations or effects. Hilllost his appeal in litigation with his sisters over a dispute about their fathers will. One form of quasi-estoppel, estoppel by contract, is based on the idea that a party to a contract cannot, to the prejudice of another, take a position inconsistent with the contract's provisions. C. Rule 12(b)(6) Motions to Dismiss Based on Estoppel. See Fed. Plain English. R2 Invs. Defendants correctly note, the filings at issue are motions, not pleadings. It is clear that Plaintiffs seek to benefit from Hassie having exercised the same power of appointment they now argue that Hill Jr. did not possess when he exercised his power of appointment in his 2014 Will. Moreover, no reasonable person would have contemplated that Hill III related litigation that was settled by the GSA and Final Judgment in 2010 would be occurring almost 12 years later. 1. In United States ex rel. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. 2004, no pet.). ; Spivey v. Robertson, 197 F.3d 772, 774 (5th Cir. Hill was the oldest grandson of legendary Texas oilman H.L. Plaintiffs themselves state in their Response at heading F: The Parties Agreed that this Action Must be Brought in this Court. Pls.' Plaintiffs' Request to Convert Pending Motions to Dismiss into Motions for Summary Judgment. Copyright 2023 ALM Global, LLC. Site Map, Advertise| Co., 511 U.S. 375, 377 (1994) (citations omitted); Home Builders Ass'n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. Compl., Doc. Hill Jr. Two of Dallas County, Texas in Estate of Albert Galatyn Hill, Jr., Deceased, PR-17-04117-2. Dynamically explore and compare data on law firms, companies, individual lawyers, and industry trends. Albert G. Hill III . The primary beneficiary of the MHTE was Margaret Hunt Hill and the primary beneficiary of the HHTE was Haroldson L. Hunt, Jr. (Hassie). Trusts: On December 7, 2017, an Application for Probate of Will and Issuance of Letters Testamentary was filed in the Estate of Albert Galatyn Hill, Jr., Deceased, in Cause No. Although often treated as effectively jurisdictional, statutory standing relates to the merits of a cause of action and not subject matter jurisdiction. Id. Trusts that were supposed to be preserved by the Final Judgment had been prematurely and unlawfully terminated by Hill Jr. and his cohorts, thereby destroying the valuable inheritance of Hill III and his descendants, from the H.L. 2008) (Estoppel . 26. Federal courts are courts of limited jurisdiction and must have statutory or constitutional power to adjudicate a claim. Both options are priced the same. They make similar allegations against Lyda Hill. Defendants contend that, insofar as they are moving to dismiss under Rule 12(b)(1) for lack of standing, Rule 12(d) does not authorize the court to convert their motion to a motion for summary judgment. A primary focus of the lawsuit was Hill III's claim to be a current beneficiary of the MHTE pursuant to Hill Jr.'s 2005 Disclaimer. 2003) (citation omitted). 2019-05-01, Tarrant County Courts | Probate | See Burke v. Barnes, 479 U.S. 361, 363 (1987). See 2020 Action, Doc. Abraham Alfonse Albert Gallatin (January 29, 1761 - August 12, 1849) was a Genevan - American politician, diplomat, ethnologist and linguist. 1994) (citation omitted). Plaintiffs contend that they and their three children (Albert Galatyn Hill IV, Nance Haroldson Hill, and Caroline Margaret Hill) are contingent or remainder beneficiaries of various trusts created as a result of the GSA and the Final Judgment. Powell v. McCormack, 395 U.S. 486, 496 (1969). Hunt, one of the worlds richest men when he died in 1974, said the opinion. I. Creating your profile on CaseMine allows you to build your network with fellow lawyers and prospective clients. As previously explained, Hill III contractually agreed in the GSA, which was incorporated into the Final Judgment, that Hill Jr.'s Disclaimer was valid and enforceable. 999 at 22-23. Steubner Realty 19, Ltd. v. Cravens Rd. In accordance with the GSA, the Final Judgment dismissed the released claims with prejudice. Margaret Hunt Hill (19152007) was an American heiress and philanthropist. and Mot. The court will also take judicial notice of matters of public record. See id. In her reply brief, Lyda Hill asserts that, in ruling on her motion to dismiss, the court is entitled to consider its own prior rulings on Plaintiffs' numerous baseless post-judgment filings. Lyda Hill's Reply 2 note 1, Doc. But when Daddy died, Hill III immediately challenged the will in probate court, ultimately forcing the Fifth Circuit to weigh in on the settlement five different times. After entry of the GSA, and in connection with discussing options for preserving Hill III's remainder interest in his new separate MHTE trust for his children, he supported an asset protection trust alternative in which he would have had the power to direct disposition of the trust assets through the power of appointment that is given to the Beneficiary under the MHTE trust. 2, Dallas County, Texas (the "Estate Action"), seeking to admit the Will to probate, and to appoint an independent executor. Moreover, to dismiss Plaintiffs' claims without prejudice would create the impression that they could file these claims in an appropriate forum when there is no other appropriate forum. 2020 Action, Doc. Lexmark Int'l, Inc. v. Static Control Components, Inc., 572 U.S. 118, 128 (2014). 203 at 4-5, 2; Doc. 2020 Action, Doc. Freeze-Related Lease Litigation: The Growing Storm in the Oil Patch, Consequential and Direct Damages in Spotlight Amid Energy Firms' Insurance Spat, 'Choppiness' in Demand Led to 2% Drop in Revenue at Locke Lord in 2022, New Phase of EPA's Renewable Fuel Standard Program: Updated Targets for 2023 - 2025 and New Credit System for EVs, Law.com Editors and Analysts Offer Top Trends to Watch for 2023. . App.-Houston [1st Dist.] Once you create your profile, you will be able to: On October 2, 2013, the 2020 Action was reassigned to the undersigned following the recusal of Judge O'Connor (who had presided over the matter for approximately sever years), which was followed by the recusals of Judges Lynn, Solis, Godbey, Boyle, Fitzwater, and Kinkeade. There are instances, however, when a dismissal for lack of standing may be with prejudice. App.-Eastland 2010, pet. Accordingly, he is not now, nor will he ever be, a current beneficiary of the Hill Jr. 1. CM-ECF citations from Hill v. Hunt et al., Civil Action No. 2007) (citing Cinel v. Connick, 15 F.3d 1338, 1343 n.6 (5th Cir. Id. which best describes the pillbugs organ of respiration; jesse pearson obituary; ion select placeholder color; best fishing spots in dupage county Accueil; Services; Ralisations; Annie Moussin; Mdias; 514-569-8476 App.-Fort Worth 2012, no pet.). Plaintiffs' Motion to Strike and Request to Convert Pending Motions to Dismiss into Motions for Summary Judgment. (citation omitted). As Lyda Hill correctly argues, [b]y these action, post-settlement, Hill III and Erin Hill confirmed that a Beneficiary' of the trusts has the very same power of appointment they now challenge with respect to the dissolution claims they bring in this lawsuit against the Hill Jr. Eckland Consultants, Inc. v. Ryder, Stilwell Inc., 176 S.W.3d 80, 87 (Tex. See Lyda Hill's Unsealed Appendix, Doc. Terms of Service. She was 91. Transfer From: Transfer In: Transfer Case: Transfer To: Transfer Out: Pub Service: West Publishing . Likewise, [d]ocuments that a defendant attaches to a motion to dismiss are considered part of the pleadings if they are referred to in the plaintiff's complaint and are central to [the plaintiff's] claims. Lets Talk: 877-396-2546; keto cereal australia coles; ghost recon breakpoint skell architecture location; how to install file manager in lg smart tv 999 at 7-9, 8.a, 9.a. on the assumption that all the allegations in the complaint are true (even if doubtful in fact). Id. The CEO of Hunt Investment Holdings on his under-the-radar favorite restaurant and why he is learning Turkish. Trusts due to the Waiver of Standing Clause: Once Hill Jr. executed his Will in 2014 dictating that, upon his death, his powers of appointment over his equitable interests in the Hill Jr. Lyda Hill makes similar arguments pertaining to the Lyda Hill trusts. Not a Bloomberg Law Subscriber?Subscribe Now. LexisNexis and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information. II, in ruling on such a Rule 12(b)(6) motion to dismiss, the court cannot look beyond the pleadings. 1876. See 2020 Action, Doc. Mann v. Adams Realty Co., 556 F.2d 288, 293 (5th Cir. albert galatyn hill iiimaryland lacrosse camps 2021. albert galatyn hill iii italian prayer for protection Kokkonen, 511 U.S. at 377 (citations omitted). By Posted does sonny's bbq serve alcohol In rule breaker snacks net worth Dallas oil heir Albert G. Hill III is now resisting the entry of that judgment in a trial court by claiming that the appellate justices got it wrong. The case status is Pending - Other Pending. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Attorney(s) appearing for the Case. The pleadings include the complaint and any documents attached to it. 999 at 6, 5; Doc. 1999). Trusts and the purported termination and dissolution of the Lyda Hill Trusts: Breach of Contract (Count One) (except as to Defendants Donnally and Tatham); Declaratory Relief (Count Two) (against all Defendants); Imposition of a Constructive Trust/Conversion (Count III) (against all Defendants); Tortious Interference with Contract (against Donnally and Tatham only) (Count IV); Breach of Fiduciary Duties and Fee Disgorgement (against Donnally, Irwin, and Tatham) (Count V); Aiding and Abetting Breach of Fiduciary Duties (against Hill Jr., Lyda Hill, Washburne, and Summers) (Count VI); Civil Conspiracy (against all Defendants) (Count VII); Aiding and Abetting (against Hill Jr., Keliher, Miller, Lyda Hill, Washburne, and Summers) (Count VIII); Unjust Enrichment (against Hill Jr., Lyda Hill, Washburne, and Summers) (Count IX); Equitable Reformation (against all Defendants) (Count X); and Exemplary Damages (against all Defendants). DocketNOTICE - CHANGE OF ADDRESS; Comment: NOTICE OF ADDRESS CHANGE OF BOURLAND, WALL & WENZEL, P.C. Trusts will not inure to Plaintiffs' benefit. United States District Court, Northern District of Texas. Based on the foregoing, the court grants Defendants' Motion to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b) (Doc. Compl., Doc. Albert G Hill, III, individually, and as a Beneficiary of the Margaret Hunt Trust Estate, derivatively on behalf of the Margaret Hunt Trust Estate, individually, As a beneficiary of the Haroldson Lafayette Hunt Jr. Trust Estate, and derivately on Behalf of the Haroldson, Plaintiff, represented by Emil Lippe, Jr. , Law Offices of Lippe & Associates & Diana . 15(a)(2), but they have discretion to grant or deny that leave and may consider a variety of factors including undue delay, bad faith or dilatory motive on the part of the movant, repeated failures to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party , and futility of the amendment. Marucci Sports, L.L.C. Sword given to a knight by a spirit of the lake. On 01/25/2022 Albert Hill, III filed an Other lawsuit against Commissioner of Internal Revenue. 1986) (affirming district court's dismissal with prejudice based on lack of standing); Westfall v. Miller, 77 F.3d 868, 871 (5th Cir. She Was Murdered On Her Way To College Fifty Eight Years In The Past Cops Lastly Know Her Killer He accuses them of placing Boo's life history on show for the edification of the neighborhood. 999-1 at 7-8. Following removal to federal court on December 3, 2007, the case was randomly assigned to Judge O'Connor. Your article was successfully shared with the contacts you provided. Leave of court to amend should not be allowed for a party to act in bad faith, cause undue delay, or pursue amendments that are futile. 879 at 21, 5(a) and Doc. Learn more about merges . Further, a court is not to strain to find inferences favorable to the plaintiff and is not to accept conclusory allegations, unwarranted deductions, or legal conclusions. Lyda Hill (born 1942). The 2005 Disclaimer further provided, among other things: On June 14, 2007, Margaret Hunt Hill died and her equitable interest in the MHTE passed in equal shares to her three children-Hill Jr., Lyda Hill, and Alinda Hill Wickert-subject to any disclaimers. and Mot. III 3 (HHTE) (emphasis added). During the May 5, 2010 hearing before Magistrate Judge Paul D. Stickney in which the parties' settlement was announced, Lyda Hill's counsel anticipated the claims Plaintiffs are attempting to relitigate in this action. Albert Gallatin Hill from tree Polasek Kennedy Wakefield Crawford Family Tree 2969 People 11 Records 14 Sources Albert Gallatin Hill found in Albert Gallatin Hill from tree Parrish Family Tree (Private) Birth xx xxx 1832 McNairy, Tennessee, USA No publicly available family members 738 People 6 Records 14 Sources Contact Tree Owner MOTION - EXCLUDE; Comment: APPLICANT'S MOTION TO EXCLUDE TRIAL EXHIBITS OF ALBERT G. HILL, III, ORDER - MISCELLANEOUS; Comment: GRANTING APPLICATION FOR ENLARGEMENT OF POWERS OF TEMPORARY ADMINISTRATOR RELATING TO THE 1298 LAWSUIT, OBJECTION; Comment: APPLICANT'S OBJECTION TO ALBERT G. HILL. Thus, as Hill III released these claims, he lacks standing to raise them in this civil action. Defendants have moved to dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6), arguing, among other things, that Plaintiffs lack standing; that Plaintiffs' claims have been settled, released, and adjudicated in the Final Judgment; and that Plaintiffs have taken positions contrary to the positions they espouse in the Complaint when it was to their benefit and are, therefore, estopped from bringing their current claims. Search all of 29Fifty Apartments's current and previously listed jobs and positions. 2020 Action, Doc. Lyda Hill's Motion to Dismiss Based on Judicial Estoppel. App.-Corpus Christi 2012, pet. The 2005 Disclaimer expressly recognized Hill Jr.'s power of appointment in the MHTE over both his income trust and his termination trust, as follows: Hill III previously argued to Dallas County Probate Court No. Trusts were dissolved in 2016, Hill III would never become a current beneficiary and any relief granted that results in money being returned to the Hill Jr. The industry-leading media platform offering competitive intelligence to prepare for today and anticipate opportunities for future success. This appeal makes it five. Hill v. Washburne, 953 F.3d 296, 301 (5th Cir. Legacy. This he does not do. Defendants contend that Plaintiffs lack standing to challenge the dissolution of the Hill Jr. Galatyn (, Garatn? Women, Influence & Power in Law UK Awards 2023, Legalweek Leaders in Tech Law Awards 2023, WORKERS COMPENSATION ATTORNEY - Hartford, CT, Offering an Opportunity of a Lifetime for Personal Injury Lawyers, What Does Your Business Agreement Really Mean? After the Probate Court had conducted hearings on those motions, Hill III nonsuited his claims without prejudice. 2020 Action, Doc. ' Funk v. Stryker Corp., 631 F.3d 777, 783 (5th Cir. Co., 509 F.3d 673, 675 (5th Cir. Resp. A. Ultimately, Hill III agreed to a settlement of the dispute. 2000). Margaret Hunt Hill was born on October 19, 1915, in Lake Village, Arkansas. Appellate Briefs . While well-pleaded facts of a complaint are to be accepted as true, legal conclusions are not entitled to the assumption of truth. Iqbal, 556 U.S. at 679 (citation omitted). See, e.g., Cutrera v. Board of Sup'rs of Louisiana State Univ., 429 F.3d 108, 113 (5th Cir.
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