It is not often that you run across a Trust Owned Life Insurance (TOLI) case in the courts. Most disputes around life insurance trusts are settled on the down-low, with a check changing hands and little publicity. That is the point. We do have the Cochran case, which provided those of us who manage these assets with some guidance, but most admit the court set the bar pretty low in that instance. Now, we have Rafert v. Meyer, a case whose lower court decision seems to set the bar so low it would be hard for a trustee to squeeze under it.