In re Wright’s Estate
7 Cal. 2d 348 (1936)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
To invalidate a will for lack of testamentary capacity, the contestant must prove either general mental incompetency or a specific hallucination or delusion that directly influenced the creation and terms of the will. Evidence of mere eccentricities, odd behaviors, or personal foibles is insufficient to establish testamentary incapacity.
Facts:
- For many years, Lorenzo B. Wright worked as a garbage wagon driver and lived alone after his wife's death in 1921.
- Wright exhibited numerous eccentric behaviors, including collecting junk from garbage cans, pinning paper flowers on his rose bushes, playing pranks like putting kerosene on a fish he gave to a neighbor, and sometimes acting strangely toward his family.
- Wright had a strained relationship with his daughter, Maud Wright Angelí, and her husband, Alma Angelí, having successfully sued to evict them from his property in 1924.
- About one year and four months before his death, Wright went to a notary public, Grace Thomas, with a self-prepared memorandum outlining his desired bequests.
- Wright executed a will that devised one house to his friend, Charlotte Josephine Hindmarch, another house to his daughter Maud, his interest in a Salt Lake City estate to his granddaughter, and one dollar each to several others, including his son-in-law.
- Lorenzo B. Wright died on May 2, 1933, at the age of sixty-nine.
Procedural Posture:
- The executrix named in Lorenzo B. Wright's will filed a petition for admission to probate in the probate court.
- Maud Wright Angelí, the testator's daughter, contested the will, alleging both undue influence and lack of testamentary capacity.
- The probate court found against the contestant on the issue of undue influence.
- The probate court denied the will's admission to probate on the ground of the testator's incapacity.
- The executrix, as appellant, appealed the probate court's judgment and order to the Supreme Court of California.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does evidence of a testator's eccentricities, odd behaviors, and moral irregularities, which do not directly bear upon or influence the creation of the will, constitute sufficient grounds to prove testamentary incapacity and invalidate the will?
Opinions:
Majority - Seawell, J.
No. Testamentary capacity cannot be destroyed by showing isolated acts, foibles, idiosyncrasies, or departures from the normal unless they directly bear upon and have influenced the testamentary act. The court reasoned that the burden is on the contestant to prove that the testator suffered from either settled insanity or specific delusions that were the direct cause of the will's provisions. In this case, the evidence presented by the contestant, which included testimony about Wright's eccentricities, drinking, and odd habits, was deemed trivial and fell far short of the legal requirement to prove incapacity. The court also held that testimony from subscribing witnesses who later claim the testator was of unsound mind should be viewed with great scrutiny and suspicion, as they are essentially repudiating their own solemn act of attestation.
Analysis:
This case reinforces the high legal standard required to invalidate a will on the grounds of testamentary incapacity, clearly distinguishing between legally significant mental incompetence and mere personal eccentricity. By strongly discrediting the testimony of attesting witnesses who recant their belief in the testator's soundness of mind, the court protects the finality of testamentary acts from being easily overturned. The decision emphasizes that a testator's will reflects their personal choices, and these choices are not to be voided simply because their lifestyle or habits are unconventional, unless a direct causal link between a specific delusion and the will's terms can be proven.
