In Estate of Ziegler (2010) 187 Cal.App.4th 1357, the decedent gave a neighbor a letter signing over his home to the neighbor in exchange for the neighbor's provision of care and meals. (Id. at p. 1361.) More than one year after the decedent's death, the neighbor filed a creditor's claim for services rendered on a quantum meruit theory and breach of contract for the value of the house. (Id. at p. 1362.) The Ziegler court found the neighbor's claims barred by section 366.3 because the claim was indistinguishable from a contract to make a will, and was a promise to transfer property on death. As the contract could only be performed after death by conveying property that otherwise belonged to the decedent's estate. (Id. at p. 1365.) In that case, the decedent executed a document signing over his home and property to his neighbor, Richard LaQue, in exchange for the continued provision of his care and daily meals. (Estate of Ziegler, at p. 1361.) The document stated that " 'this written note will be immediately active if and when I no longer can reside in my home due to death.' " (Ibid.) On January 15, 2006, the decedent died, and in September 2006, the public administrator filed a petition to probate the decedent's estate. More than one year after the decedent's death, LaQue filed a creditor's claim for $9,556, representing the value of his services on a quantum meruit theory. Less than a week later, LaQue filed an alternative creditor's claim for $318,600, the estimated value of the house, representing the value of his services on a contract theory. Although the Court of Appeal noted that the equities were entirely on the side of LaQue rather than the company representing German nationals who were the decedent's closest heirs, the court rejected LaQue's claims on the basis that they were barred by the statute of limitations set forth in section 366.3, subdivision (a). (Estate of Ziegler, at p. 1366.) The court noted that generally section 366.3 "has been construed to 'reach any action predicated upon the decedent's agreement to distribute estate or trust property in a specified manner.' " (Estate of Ziegler, supra, 187 Cal.App.4th at p. 1365.) The court stated that the term " 'distribution' " typically refers to the disbursement of assets to heirs. (Ibid.) And although one does not normally use "distribution" to refer to the payment of a creditor's claim or the award of specific property to a person who is claiming it as the true owner, "the Legislature clearly intended ... section 366.3 to apply, at a minimum, to a claim based on a contract to make a will," referring broadly in the legislative history to all " 'equitable and contractual claims to distribution of estates.' " (Ibid.) The court "assumed ... that a claim based on a contract to make a will is either a creditor's claim or a claim to specific property and hence is not a claim for a 'distribution' in the technical sense," but it is "a claim for a 'distribution' in the sense that the Legislature intended" with respect to the enactment of section 366.3, subdivision (a). (Estate of Ziegler, at p. 1365.) The court determined that LaQue's claim was "indistinguishable from a claim on a contract to make a will. The Agreement was a promise to transfer property upon death. It could be performed only after death, by the decedent's personal representative, by conveying property that otherwise belonged to the estate." (Estate of Ziegler, supra, 187 Cal.App.4th at p. 1365.) And the court held that even if the written agreement was viewed as a present obligation to convey a distribution of the estate, it would still come within the scope of section 366.3. Accordingly, the court concluded that LaQue's claims, filed more than one year after the decedent's death, were time-barred by section 366.3. (Estate of Ziegler, at p. 1366.)