British Columbia Court of Appeal Decides Mawdsley v. Meshen

In a decision released on February 28, 2012, the British Columbia Court of Appeal held that the transfer by Joan Meshen of a substantial portion of her wealth into an alter ego trust was not a fraudulent conveyance intended to defeat the claims of her common law spouse, Dennis Mawdsley. Mawdsley v. Meshen, 2012 BCCA 91, is the first reported Court of Appeal case dealing with a challenge of a transaction under the Fraudulent Conveyance Act brought by a Wills Variation Act claimant in order to bring assets back into the estate of a deceased person so that those assets would be subject to the claimant’s Wills Variation Act claim.

In upholding Madam Justice Ballance’s decision at trial, which is reported at 2010 BCSC 1099, the Court of Appeal made two rulings that are likely to have a significant impact on estate planning. First, the Court of Appeal held that the fact that a transfer of assets may have the effect of defeating a claim does not require the court to find that the person making the transfer intended to do so. For a transaction to be a fraudulent conveyance, the transferor must have the intent to delay, hinder or defraud someone. Secondly, the Court of Appeal upheld a number of Supreme Court of British Columbia decisions that a person who does not have a claim during his or her parent or spouse’s lifetime, and whose only claim arises on the death of the parent or spouse under the Wills Variation Act, is not a “creditor or other” with standing to challenge a transfer by their parent or spouse.

Joan Meshen had considerable wealth, much of which she accumulated together with, or received from, her late second husband, who died in 1983. Her assets included real estate properties in Greater Vancouver, and shares in three companies. She had three children, Shirley Meshen and Harry Meshen from her first marriage and Michael Meshen from her second marriage.

In February, 2006, Ms. Meshen was diagnosed with cancer.

After her diagnosis, she made a new will, transferred property to her children, and transferred a $3,250,000 investment account and the shares of her three companies into an alter ego trust. The trust provided that during her lifetime she would receive all of the income from the trust assets. On her death the beneficiaries of the trust were her three children, and her second husband’s brother, Bill Meshen, who had been active in the family business. She died shortly thereafter.

Ms. Meshen made no provision for her common-law spouse of 18 years, Dennis Mawdsley, either in her will, or by a transfer of property before her death.

Mr. Mawdsley brought a Wills Variation Act claim. The Wills Variation Act provides that a spouse or child may apply to court to vary the will if the will-maker did not make adequate provision for the claimant. The court may then vary the will to make such provision as the court decides is “adequate, just and equitable in the circumstances.” The Wills Variation Act allows the court to vary the will, but does not give the court the power to vary a trust settled during the will-maker’s lifetime. Because the Wills Variation Act only applies to assets that fall into the estate, there would be little for Mr. Mawdsley to claim unless he were successful in challenging the transfers Ms. Meshen made before her death, including the tansfer of assets to the trust.

In dismissing Mr. Mawdsley's claim that the transfer of assets into the trust was a fraudulent conveyance at trial, Madam Justice Ballance found that Joan Meshen was not motivated by an intention to defeat any claim by Mr. Mawdsley in setting up the trust. Although her lawyer had told her that Mr. Mawdsley had a potential Wills Variation Act claim, Ms. Meshen dismissed the idea that her common law husband would make such a claim. She said that she and Mr. Mawdsley had an agreement that each would keep her or his property. Madam Justice Ballance found that they did have an agreement that apart from sharing some expenses, they would keep their property separate, and each was free to deal with her or his own property.

Furthermore, Mr. Mawdsley had been in on meetings with Joan Meshen’s estate-planning advisers as far back as 2000 in which she had discussions about transferring assets into a trust to benefit her children and Bill Meshen. He knew that she did not intend to leave him anything, and he did not object during her lifetime.

One of the arguments that Mr. Mawdsley made on appeal was that if the effect of the transfer was to remove assets from her estate, then as a matter of law, she must have intended to delay, hinder or defraud him. Madam Justice Newbury rejected this argument. Although the person challenging a transaction as a fraudulent conveyance only needs to show that one of the purposes of the transaction is to delay or hinder creditors, and in some cases the court may infer from the effect of the transfer that the transferor intended to delay or hinder creditors, the court may consider evidence that the transferor had no such intent. Madam Justice Newbury wrote at paragraph 71,

In some cases, of course, that intention may be inferred from the effect of the transaction, and indeed a presumption may arise in some circumstances from that effect. If there is no credible evidence to the contrary, the FCA [Fraudulent Conveyance Act] may be satisfied; but there is no rule of law that in every case, an intention to defeat creditors must be inferred from the effect of the impugned transaction

In this case, the Court of Appeal upheld the trial judge’s finding that Ms. Meshen did not intend to hinder Mr. Mawdsley.

The second-- and from an estate-planning perspective the most significant holding-- is that Mr. Mawdsley was not a “creditor or other” within the meaning of the Fraudulent Conveyance Act.

At trial, Madam Justice Ballance found that during Ms. Meshen’s lifetime, Mr. Mawdsley did not have any legal claim to her assets. Because they were not married, he had no claim under the Family Relations Act, and the court found that he had not made sufficient contributions to the family business or to Ms. Meshen to be entitled to make a claim in unjust enrichment. His only claim was a Wills Variation Act claim, which only arose on Ms. Meshen’s death. In fact he was successful in varying the will.

In a few cases brought by children challenging transfers of assets made by their parents under the Fraudulent Conveyance Act in order to have the assets brought into the estate so that they would be subject to Wills Variation Act claims, the Supreme Court of British Columbia has held that the children did not have grounds to apply under the Fraudulent Conveyance Act, a potential Wills Variation Act claim being an insufficient basis to give the child standing as a “creditor or other” to set aside the transactions. These cases include Hossay v. Newman (1998), 22 E.T.R. (2d) 150 (B.C.S.C.) and Mordo v. Nitting, 2006 BCSC 1761.

Estate planners have relied on these cases in setting up estate plans for parents concerned that their adult children will try to upset their estate plans by bringing Wills Variation Act claims. A parent can transfer assets into a trust during the parent’s lifetime to provide for the parent’s spouse, to provide more for some children than others, or to provide for charity. Because the Wills Variation Act does not apply to a trust settled during the parent’s lifetime, a disappointed adult child will not able to use the Wills Variation Act to gain assets that were transferred to the trust. This was done in Mordo by a mother who wished to leave her wealth to her daughter to the exclusion of her estranged son.

In Mawdsley v. Meshen, the Court of Appeal has now upheld these earlier Supreme Court of British Columbia decisions, including Hossay and Mordo.

Madam Justice Newbury considered the implications of Mr. Mawdsley’s argument that Ms. Meshen had a moral obligation to him pursuant to the Wills Variation Act that crystallized at her death, and on the basis of which he argued he should have standing as a “creditor or other” to challenge the transfer of assets into the trust as a fraudulent conveyance:

[90] This argument may conform to one’s moral sense in a particular case, but as has been seen, no case has gone so far as to suggest that “creditors and others” in the FCA includes a person who has no claim at the time of the transfer in question ‒ or for that matter, during the transferor’s lifetime. The implications of so interpreting the phrase would be enormous. Persons qualifying as spouses or children under the WVA would be entitled, at least prima facie, to challenge every disposition of property, whether for valuable consideration or not, made by their spouse or parent during his or her lifetime, and even to seek to prevent such dispositions by court action. The courts would find themselves assessing the consequences of various forms of transfers, including dispositions in the course of business, dispositions carried out years earlier and dispositions proposed to be carried out in the future, all in the name of protecting “moral” obligations that cannot truly be judged until the parent or spouse has lived his or her life and died leaving an estate and a will. I cannot imagine that courts should take on this role of arbiter of personal and business decisions throughout a parent or spouse’s lifetime without the Legislature’s clearly directing us to do so.

Although Mawdsley lends support for using trusts to avoid Wills Variation Act claims, it is important to note that a key to this decision was the initial finding at trial that Ms. Meshen did not have any legal obligations to Mr. Mawdsley during her lifetime. In other cases, transactions may still be set aside under the Fraudulent Conveyance Act by claimants under the Wills Variation Act if those claimants can show that the transaction was intended to defeat a legal obligation that the will-maker had to them during the will-maker’s lifetime. For example, if the person making a transfer does so with the intent to delay or hinder the legal claims of his married spouse under the Family Relations Act, or claims of a common law spouse or child in unjust enrichment, then the transfer to a trust is liable to be set aside as a fraudulent conveyance if the spouse or child had a valid legal claim.

University of Manitoba v. Sanderson Estate

Mutual wills refer to wills made by two people who agree that after the death of the first of them to die, the survivor will either not change his will, or he will not change certain gifts in his will.

For example, spouses in a second marriage may leave each other all or most of their wealth in their wills. The husband may provide that if his wife had died before him, half of his estate will go to his own children, and half to hers. The wife makes a similar will. The idea is that eventually the wealth remaining on the death of the last to die will be divided so that half of the wealth goes to the husband’s children, and half to the wife’s.
These are mirror image will’s, but not necessarily mutual wills.

If in our example, the husband and wife also make an agreement that neither of them will change their wills (or change the gifts to the other spouse’s children) after the other’s death, then the wills are mutual wills. In British Columbia, if the last to die then changes his or her will contrary to the mutual will agreement, then those whose interests are harmed by the change can sue to enforce the agreement.

Mutual will agreements raise a number of issues. For example, what if the surviving spouse doesn’t change his will, but gives away his assets during his lifetime. The will remains, but there is little or nothing left for his wife’s children to inherit. How can they assert any claim?

Mutual wills are not very common in British Columbia. Most of the court cases concerning mutual wills involve the question about whether the spouses entered into a mutual will agreement, or whether the survivor was free to make a new will. Absent clear language either in the will, or in a separate agreement, the courts in British Columbia have usually found that the spouses did not intend to bind themselves. I should note that although mutual wills usually involve wills made by either married or common-law spouses, any two people can make mutual wills.

One of the leading mutual will cases in British Columbia is University of Manitoba v. Sanderson Estate, (1998), 155 D.L.R. (4th) 40 (BCCA). In contrast to my examples, this case does not involve gifts to children made by spouses in second marriages. The intended beneficiary was a charity: the University of Manitoba.

Michael Sanderson and Katherine Sanderson each made wills on July 9, 1970, in which they each provided that his or her estate would be held in trust for the other for life, and then on the death of the last of them to die, their estates would go to the University of Manitoba. They also signed an agreement that provided that neither would change his or her will during their joint lives without the other’s agreement. After the death of one of them, the survivor agreed he or she would not change his or her will. They changed their executors and made minor changes to their wills by codicils while they were both alive.

Mrs. Sanderson died first on July 18, 1985. By that time, most of the Sandersons’ assets had been acquired by them after they made their mutual will agreement and were held in joint tenancies, with right of survivorship. This meant that the interest Mrs. Sanderson held in their assets flowed to Mr. Sanderson outside of her estate. Her executor did not even need to probate her will, because there was little or nothing in her estate.

After Mrs. Sanderson’s death, Mr. Sanderson changed his will to leave some of his estate to friends and family, thereby reducing the University’s share.

When Mr. Sanderson died, the University of Manitoba sued, seeking to uphold the mutual wills and assert against the other beneficiaries of Mr. Sanderson’s will, the University’s right to receive the whole of his estate under the mutual will agreement.

Some of Mr. Sanderson’s beneficiaries argued that because Mr. Sanderson did not receive a benefit under Mrs. Sanderson’s will (the assets flowing to him as the surviving joint tenant instead), he was not bound by the mutual will agreement after his wife’s death.

Although Mr. Sanderson’s other beneficiaries were successful at trial, the Court of Appeal rejected this argument, and held that it was not necessary for Mr. Sanderson to benefit from his wife’s will for him to be bound by the mutual will agreement. This is because it is sufficient that Mrs. Sanderson relied on the agreement in keeping her will, and it would be inequitable to allow Mr. Sanderson to change his will after she kept her will in reliance of the agreement.

Madam Justice Rowles wrote at paragraphs 44 through 46:

[44] With respect, I do not agree that either the probate of the will of the first to die, or a benefit flowing to the survivor from the will of the other, is a necessary condition for relief to be granted to the University on trust principles.

[45] This is a case in which there was an express agreement made that the mutual wills would not be revoked or altered during the joint lives of the parties to the agreement and that after the death of the first, the will of the survivor would not be altered or revoked. There was an exchange of promises and Mrs. Sanderson did not revoke her will, although she had the legal right to do so, before her death.

[46] The guiding principles to be applied in this case are to be found in Dufour v. Pereira, supra, in which the enforcement of an agreement in a joint will was held to be within equity's jurisdiction to prevent fraud. Equity considers it a fraud upon the deceased, who has acted upon and relied upon the mutually binding nature of the agreement, for the survivor to change the will and break the agreement. As the deceased cannot intervene to enforce the obligation, equity will enforce the survivor's obligation, despite the survivor's subsequent intentions.

The Court of Appeal agreed with the University of Manitoba. Because it would be against good conscience to allow Mr. Sanderson to change his will contrary to the mutual wills agreement, the Court of Appeal imposed a remedial constructive trust on his estate in favour of the University of Manitoba.

Ottawa Courthouse

I took this photograph of the Ottawa Courthouse in October, 2011, while I was attending the Canadian Bar Association, National Wills, Trusts and Estates Section  Executive meeting. Below is a somewhat more scenic photograph I took from my hotel room of the Parliament Buildings:

Can an Executor Use Estate Funds to Defend a Wills Variation Act Claim if the Will Directs Him To Do So?

As I have written before, when a child or spouse applies to vary a will under the Wills Variation Act in British Columbia, an executor must remain neutral. A Wills Variation Act case is a dispute among those claiming under the Act and the beneficiaries of the will. It is not a claim against the estate entitling the executor of the will to use estate funds to defend the claim.

In a decision released on Friday, February 3, 2012, Mr. Justice Wong gave reasons for judgment in an application by an executor for directions as to whether he may defend against a Wills Variation Act claim to vary a will. The requirement that an executor remain neutral is well established, but this case, Ketcham v. Walton, 2012 BCSC 175, has an interesting twist to it: the will directed the executor to defend against any claim under the Wills Variation Act, and if necessary to deplete the estate and take appeals to defend the will.

Eric Worthy Clay disinherited his three children, leaving his estate of just under $800,000 to friends and charities. In his will, he said that his children were estranged from him, and he directed his executor, Mr. Kenneth Walton QC, to defend against any Wills Variation Act claim. After his death, his children did apply to court under the Wills Variation Act to vary the will.

One of the arguments put forward for allowing the executor to defend against the Wills Variation Act claim was that the residual beneficiaries who would receive about $277,000, and whose interests were most likely affected, had not filed a response to defend against the claim.

Despite this clause directing the executor to defend, Mr. Justice Wong held that the executor must remain neutral. He held that the principle that an executor must remain neutral overrides the direction in the will. Furthermore, the provision that the executor may deplete the estate funds is void as being against public policy because the clause may discourage the children from having their case heard in court. If the executor is entitled to deplete the entire estate on defending the claim, the children could be denied any recovery even if successful.

But-- and this is I think a development in the law-- Mr. Justice Wong did say that if the Wills Variation Act claim is not being defended by the beneficiaries, “[i]n order to assist the Court in determining the merits of the plaintiffs’ WVA claim in a balanced and non adversarial role, the Executor might then retain counsel as Amicus for the Court with respect to questioning the plaintiffs’ claim for assistance of the Court.”

As I interpret Mr. Justice Wong’s decision, an executor usually has a very limited and neutral role in a Wills Variation Act case. The persons making a claim and the beneficiaries are the main parties to the dispute. But in appropriate cases, the executor may play an active role, but in a non-adversarial manner.

Mr. Justice Wong does not flesh out the specific things an executor or his lawyer might do as a friend of the court, but I suggest that in some cases it may be appropriate for the executor to lead evidence about the will-maker’s reasons for making the provisions he or she did in the will, and perhaps to have a lawyer cross-examine witnesses.

I can conceive of Wills Variation Act cases where it would be appropriate for an executor to lead evidence of the will-maker’s intentions and to question a claim. For example, suppose a mother has two children: a daughter who functions well, and a son who has a drug addiction. The mother leaves half of her estate to her daughter. She wishes to provide for her son as well, but is concerned that if she makes an outright gift to him, he will use it for drugs, thereby harming him. The mother provides in her will that the other half is to be held by a trustee who has discretion to make payments to or for the benefit of her son during his lifetime, with any funds remaining on her son’s death paid to a charity. The trustee can then use half of the estate to benefit the son, without the son getting control of the funds to feed his addiction. The son brings a Wills Variation Act claim seeking to vary the will so that he receives one-half of the estate outright, instead of it going into a trust. The daughter does want to spend her money on legal fees to defend against her brother’s claim given that he is only seeking half of the estate. The charity is reluctant to get involved in a family dispute, or spend funds when there may be nothing left for the charity in the trust after the son’s death in any event. In circumstances such as set out in these hypothetical facts, the executor should be allowed to spend funds out of the estate to provide the court with evidence of the mother’s reasons. The son could then lead evidence as to whether he does in fact suffer from a drug addiction, and the executor’s lawyer could cross-examine the son and the son’s other witnesses so that the court has sufficient evidence to decide whether to vary the will.

But before using funds estate funds to play an active role in a Wills Variation Act case, an executor is well-advised to seek directions from the court as Mr. Walton did in Ketcham v. Walton.

Advance Directives and Representation Agreements

The Canadian Bar Association, British Columbia Branch has published my article "Advance Directives and Representation Agreements: How do they differ?" in the February 2012 edition of Bartalk.

In an advance directive you can give or refuse consent to specific types of health care in case you later become incapable of making your own decisions.

In a representation agreement you can appoint someone to make health care and personal care decisions for you if you become incapable.

What happens if you make an advance directive concerning a health care matter over which you have also given your representative authority in a representation agreement? Which has priority? Does the advance directive supersede your representative's authority, or must a health care provider still consult with your representative?

You can find out by reading my article here.

McPeake v. Canada (Attorney General)

If a trust agreement does not accurately reflect the intentions of the parties creating the trust, the trustees may make an application to court to rectify the trust. The power to rectify a trust may be used to save the parties from significant taxes that they would otherwise have to pay. Taxpayers sometimes employ trusts to arrange their affairs to minimize income tax. Provided it is not a sham or done to hide property or income, the use of trusts to minimize income tax is legal in Canada. But transferring property to a trust can be tricky: if it is not set up just right, the terms of the trust may run afoul tax provisions that can result in a big and unexpected tax bill.

Barry McPeake owned one-fifth of the shares in a software development company in the 1990s. After receiving tax advice, he transferred his shares in the company to a family trust, of which he, his wife, and a legal advisor were the trustees. Members of his family were the beneficiaries of the trust. The purpose of the trust was to avoid tax if the shares were sold. Growth in the value of the shares could be allocated to the beneficiaries, who could then each use a capital gains exemption, which at that time was $500,000 on qualifying shares. The effect was that instead of there only being one $500,000 exemption available to Mr. McPeake when the shares were sold, there would be several $500,000 exemptions, significantly reducing capital gains tax.

The software development company was sold to Microsoft in 1999. Mr. McPeake’s family trust received $3,950,000 for its shares.

Canada Customs and Revenue Agency assessed Mr. McPeake for income tax on income and capital gains in respect of the shares after he transferred the shares to his family trust. The reason was that the terms of the trust document was caught by section 75(2) of the Income Tax Act, which is one of several sections containing rules that attribute income to someone who has transferred property.

In a nutshell, if after you transfer property to a trust, the terms of the trust permit the property to revert to you, or allow you to determine who the property can pass to, or if your consent is required to dispose of the property, income and capital gains are attributed back to you during your lifetime. The section says:

75. (2) Where, by a trust created in any manner whatever since 1934, property is held on condition

(a) that it or property substituted therefor may

(i) revert to the person from whom the property or property for which it was substituted was directly or indirectly received (in this subsection referred to as “the person”), or

(ii) pass to persons to be determined by the person at a time subsequent to the creation of the trust, or 

(b) that, during the existence of the person, the property shall not be disposed of except with the person’s consent or in accordance with the person’s direction,

any income or loss from the property or from property substituted for the property, and any taxable capital gain or allowable capital loss from the disposition of the property or of property substituted for the property, shall, during the existence of the person while the person is resident in Canada, be deemed to be income or a loss, as the case may be, or a taxable capital gain or allowable capital loss, as the case may be, of the person.

Canada Customs and Revenue Agency identified several ways in which the trust was caught by section 75 (2), some of which were fixed in a rectification proceeding in 2009, which Canada Customs and Revenue Agency did not oppose. But problems remained after the 2009 rectification. The terms of the trust required that the trustees must make decisions unanimously, which means that Mr. McPeake would have to consent to any disposal of the trust property. McPeake could also become the sole trustee, which would enable him to determine beneficiaries after the creation of the trust.

The trustees applied to the Supreme Court of British Columbia to rectify the trust document to rectify those provisions that triggered attribution under section 75(2) in McPeake v. Canada (Attorney General), 2012 BCSC 132. This time the government opposed the rectification.

In her decision, Madam Justice Dorgan neatly summarized British Columbia law on rectification as follows:

[16] Rectification is an equitable remedy that courts may apply to various legal documents that stand as instruments expressing intended legal relations. Rectifiable documents can include contracts (Performance Industries Ltd. v. Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, 1 S.C.R. 678 (“Performance Industries”)), land deeds (771225 Ontario Inc. v. Bramco Holdings Co. (1994), 17 O.R. (3d) 571 (Gen. Div.) (“Bramco SC”)), documents relating to corporate transactions (Juliar v. Canada (Attorney General) (1999), 46 O.R. (3d) 104 (Sup. Ct.) (“Juliar SC”)), and trust deeds (Rose v. Rose (2006), 81 O.R. (3d) 349 (Sup. Ct.)). Rectification does not change the intended legal relation: it would not, for example, change the essence of the agreement between contracting parties. Rather, rectification changes an instrument’s mistaken expression of that intention. Rectification is restorative, not “retroactive”: “[Rectification] is to restore the parties to their original bargain, not to rectify a belatedly recognized error of judgment by one party or the other” (Performance Industries, para. 31). Since rectification restores a truth to an instrument’s expression, it acts, in time, from the point of instrument formation forward.

[17] The party seeking rectification bears the onus. For the court to exercise its equitable jurisdiction to rectify a document, a petitioner must satisfy the court that the request to rectify merely aligns the document with the true intentions underlying it, and that the aspects to be rectified are mistakes that obstruct the true intentions behind the document’s formation. Long before Binnie J. discussed rectification in Performance Industries, Vice-Chancellor W. M. James wrote in Mackenzie v. Coulson, (1869) L.R. 8 Eq. 368 at 375, “Courts of Equity do not rectify contracts; they may and do rectify instruments purporting to have been made in pursuance of the terms of contracts.”

[18] As set out in Bank of Montreal v. Vancouver Professional Soccer Ltd. (1987), 15 B.C.L.R. (2d) 34 (C.A.) at 36 - 37 (“Bank of Montreal”) by McLachlin J.A. as she then was, a petitioner for rectification of any document must establish:

1. that the written instrument does not reflect the true agreement of the parties; and
2. that the parties shared a common continuing intention up to the time of signature that the provision in question stand as agreed rather than as reflected in the instrument.
See: Joscelyne v. Nissen, [1970] 2 Q.B. 86 at 98 - 99, [1970] 2 W.L.R. 509, [1970] 1 All E.R. 1213 (C.A.); Frederick E. Rose (London) Ltd. v. William H. Pim Junior & Co., (1953), 2 Q.B. 450 at 451, [1953] 3 W.L.R. 497, [1953] 2 All E.R. 739 (C.A.).

The intention underlying the document must be more than a general intention. Exactly what constitutes sufficient specificity of intention varies by context.

In this case, Madam Justice Dorgan found that Mr. McPeake and the other parties to the trust had a sufficiently specific intention in creating the trust of maximizing capital gains exemptions on the shares of the company for the court to rectify the trust document to correspond with that intention. Accordingly, she ordered the trust document rectified so that the income and capital gains would not be attributed back to Mr. McPeake.

Canadian Centre for Elder Law Announces 2012 Canadian Conference on Elder Law

The Canadian Centre for Elder Law has announced that it is holding the 2012 Canadian Conference on Elder Law on November 16 and 17 in Vancouver, B.C. According to the press release:

The Canadian Centre for Elder Law is pleased to announce the 2012 Canadian Conference on Elder Law is taking place November 16 to 17, 2012. This is the sixth elder law conference hosted by the CCEL, and for 2012 the Conference returns to beautiful downtown Vancouver, British Columbia. We hope you will join experts, academics, lawyers and advocates from across the globe to advance the discussion of elder law issues.

Over the years this inter-disciplinary event has been a site for discussion of issues of interest to practitioners working in law, policy, government, policing and justice, health care, finance, education and front line advocacy. The theme for this year's conference is "Advocacy and Aging: From Storytelling to Systemic Change."

The conference pre-day, the World Study Group, will be held November 15, 2012. The World Study Group offers scholars an opportunity to share their research and ideas with academics from around the world.