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Keywords

burden of proofwill

burden of proofprobatewill

Related Cases

In re Estate of Angle, 777 A.2d 114, 2001 PA Super 144

Facts

Amos A. Angle, a widower, died testate on October 31, 1997, at the age of eighty-three. His will, dated April 14, 1997, was contested by three of his children who alleged that he lacked testamentary capacity due to Alzheimer's disease and that the will was procured by undue influence from other children. The orphans' court found that the will reflected Mr. Angle's true intentions regarding the distribution of his estate, which included provisions favoring his children who did not own homes.

Amos A. Angle, a widower, died testate on October 31, 1997, at the age of eighty-three years. His will was dated April 14, 1997, and was probated on June 22, 1998, by the Franklin County Register of Wills.

Issue

Did the testator, Amos A. Angle, lack testamentary capacity at the time of executing his will, and was the will procured by undue influence from his children?

Rule

To establish a prima facie case of undue influence, three elements must be proven: 1) a confidential relationship between the proponent and testator; 2) the proponent receives a substantial benefit under the will; and 3) the testator had a weakened intellect.

A prima facie case of undue influence is established and the burden of proof is shifted to the will's proponent when three elements are established: 1) there was a confidential relationship between the proponent and testator; 2) the proponent receives a substantial benefit under the will; 3) the testator had a weakened intellect.

Analysis

The court analyzed the evidence presented, noting that while Mr. Angle suffered from Alzheimer's disease, this alone did not establish incompetency. Testimonies from disinterested witnesses indicated that Mr. Angle was clear about his intentions and desires regarding the distribution of his estate. The court found no evidence of manipulation or control over Mr. Angle's decisions, concluding that he was competent at the time of the will's execution.

The credible evidence does not support the contestants' assertions that he was dominated or manipulated by anyone, including the proponents.

Conclusion

The court affirmed the orphans' court's decision, holding that the will was valid and not the product of undue influence, as the contestants failed to meet their burden of proof.

The orphans' court correctly concluded that contestants had failed to present a prima facie case establishing that the favored distributions were procured by undue influence.

Who won?

The proponents of the will prevailed because the court found that the will reflected the true intentions of the testator and that the contestants did not establish undue influence.

The orphans' court found specifically that '[t]he undisputed evidence showed Mr. Angle knew the general economic standing of all his adult children, particularly that Libby and Martha were his only children lacking homes of their own.'

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Keywords

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Steele v. Chase, 151 Ind.App. 600, 281 N.E.2d 137

In re Harrison’s Estate, 316 Pa. 15, 173 A. 407, 94 A.L.R. 1019

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Martina v. Elrod, 293 Ga. 538, 748 S.E.2d 412, 13 FCDR 2811