T&E Solo Pack · California · Weeks Of June 1 and June 8, 2026

California.

Your state's pack. New issues arrive periodically on Mondays. Bookmark it. I built this for the California T&E solo who knows the Probate Code cold but still loses an afternoon a week tracking the moving Medi-Cal pieces.

For licensed attorneys. This pack is general legal information and professional commentary for practicing attorneys — it is not legal advice, does not apply to any specific matter, and creates no attorney-client relationship. Verify every authority against the cited primary source before relying on it with a client. Published by Mike Moss, a Utah-admitted attorney, as an AI-enablement information product; it is not an offer of legal services and is not a representation that the author is admitted to practice in your jurisdiction.

CA
California · Golden State
UPC — No (own Probate Code)
Community Property — Yes
LTC — Medi-Cal (ALW / HCBA)
Estate Recovery — Probate-only
T&E Solo Pack Built for California attorneys
The Big Three · Weeks Of June 1 and June 8, 2026

Here's what I'd want you to see from last week.

Three developments I think actually matter to a California T&E solo. Each has a read that lands on your practice specifically — and each comes with a reachable citation so you can verify it yourself before you use it with a client.

01

Medi-Cal estate recovery still reaches only the probate estate.

Since deaths on or after January 1, 2017, California recovers Medi-Cal costs only against probate assets (SB 833; Welf. & Inst. Code § 14009.5).

This is the structural fact a California Medi-Cal plan is built around. A funded living trust is the recovery shield; the malpractice trap is the unfunded trust.

Cal. Welf. & Inst. Code § 14009.5 · leginfo.legislature.ca.gov

02

The Medi-Cal asset limit returns January 1, 2026.

After the 2022–2024 phase-out, the asset limit returns at $130,000 for one person.

For a California solo this re-opens a planning practice that had gone dormant. AB 116 (Ch. 21, Stats. 2025); DHCS ACWDL 25-18 & 25-20.

Cal. Assembly Bill 116 (Ch. 21, Stats. 2025) · dhcs.ca.gov

03

The 2026 federal figures are set.

Maximum CSRA is $162,660 (minimum $32,532); California applies the higher $1,130,000 home-equity limit.

Two places this lands: community-spouse protection math and high-value-home clients. Flag the 2028 H.R. 1 change now.

42 U.S.C. § 1396p · CMS 2026 Standards (medicaid.gov)

From the Courts · Recent · California

What the courts did — and what it changes at your desk.

Decisions from the courts that bind a California practitioner — the Supreme Court of California and the Courts of Appeal, the U.S. District Courts in California, and the Ninth Circuit — read for what actually changes how you draft, advise, and plan. Trusts and estates broadly, not Medicaid alone: wills and capacity, undue influence, fiduciary duty, trust construction, and estate recovery. One read, the holding, and the official cite.

Decided June 9, 2026
Cal. Court of Appeal, 2d Dist.
Certified for publication

In re Tung Trust — a boilerplate 30-day survival clause did not override the antilapse statute, so a predeceased child’s issue still take.

The settlor’s revocable trust left “all real property” to her son, who predeceased her; the trust had no residuary or alternate-disposition clause and never mentioned his children. The successor trustee petitioned to have the gift fail (sending the property to intestacy), and the probate court agreed on summary adjudication. The Court of Appeal reversed: California’s antilapse statute (Probate Code § 21110) substitutes a predeceased transferee’s issue unless the instrument expresses a “contrary intention.” A generic “survive by 30 days, else deemed to have predeceased the settlor” clause merely defines predecease — it does not say the gift fails or that the issue are cut off — so it is not the clear contrary intention needed to defeat antilapse. The son’s children take his share.

Drafting and administration takeaways. One: a generic survivorship clause is not an antilapse override — if a client wants a gift to lapse (rather than pass to the beneficiary’s descendants) when the beneficiary predeceases, say so expressly. Two: pair every specific gift with an alternate-disposition/residuary clause; the missing residuary is what sent this to an antilapse fight. Three: in administration, before treating a predeceased beneficiary’s gift as failed, run § 21110 and check for issue who stand in the beneficiary’s place.

In re Tung Trust Dated October 24, 2011, No. B343197 (Cal. Ct. App., 2d Dist. June 9, 2026) (certified for publication) · official opinion — courts.ca.gov

Weeks Of June 1 and June 8, 2026

This week.

This week in California for the T&E solo with Medi-Cal-planning clients: what the State Bar of California, county bars, and DHCS bulletins put in front of you.

The State Bar CLE calendar, the Trusts and Estates Section, and the DHCS bulletins all publish on different schedules. This is that sift, already done, with the link on each item.