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Keywords

appealtrialverdicttestimonymotionwill
appealtrialverdictmotionwillcircumstantial evidencemotion for directed verdict

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Andrews v. Rentz, 266 Ga. 782, 470 S.E.2d 669

Facts

William J. Bignon, Jr. died in 1993, leaving behind an estate valued at approximately $150,000 and two residences. His first will from 1988 left the bulk of his estate to his granddaughter, while his later will from 1991 left everything to his caretaker, Mary W. Rentz, and only $200 to his daughter, Patricia Ann Bignon Andrews. Andrews filed a caveat against the 1991 will, claiming undue influence and lack of testamentary capacity, leading to a trial where the court ultimately directed a verdict in favor of Rentz.

William J. Bignon, Jr. died testate in 1993 at the age of 83. His estate consisted of approximately $150,000 on deposit and two residences valued in excess of $100,000.

Issue

Did the trial court err in directing a verdict in favor of the will propounder, and was there sufficient evidence to support claims of undue influence and lack of testamentary capacity?

Did the trial court err in granting Rentz's motion for directed verdict because sufficient circumstantial evidence regarding lack of testamentary capacity and undue influence was presented to go to the jury?

Rule

A directed verdict is appropriate when there is no conflict in the evidence regarding any material issue, and the evidence demands a particular verdict. Testamentary capacity requires a showing of a total absence of mind at the time of the will's execution, while undue influence must be shown to have destroyed the testator's free agency.

A directed verdict is authorized when 'there is no conflict in the evidence as to any material issue and the evidence introduced, with all reasonable deductions therefrom, shall demand a particular verdict.'

Analysis

The court found that the evidence presented did not demonstrate a lack of testamentary capacity at the time the will was executed. Testimony indicated that although Bignon experienced some mental decline, he was oriented and able to comprehend. Regarding undue influence, while Rentz had a confidential relationship with Bignon, there was no evidence that she coerced or influenced him in making the will. The consistency of Bignon's bequests in both wills further supported the court's decision.

The evidence presented at trial indicated that Rentz had a confidential relationship with Bignon and was present during the execution of the 1991 will. However, no evidence indicated that Rentz had any discussions with Bignon regarding the disposition of his estate, participated in the testamentary planning, or requested or coerced Bignon to make such disposition, or that Bignon felt coerced to make the disposition that he did.

Conclusion

The Supreme Court affirmed the trial court's judgment, concluding that Andrews's appeal from the denial of her motion for a new trial was dismissed and that the evidence did not support her claims of undue influence or lack of testamentary capacity.

Judgment affirmed in Case No. S96A0569; appeal dismissed in Case No. S96A0571.

Who won?

Mary W. Rentz prevailed in the case because the court found that the evidence did not support the claims of undue influence or lack of testamentary capacity, and the directed verdict was appropriate.

The trial court correctly granted a directed verdict on this issue.

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