Beckwith v. Dahl
California Court of Appeal
141 Cal. Rptr. 3d 142 (2012)
Brent Beckwith (plaintiff) and Marc MacGinnis were in a cohabiting, longtime relationship. MacGinnis’s only living relative was an estranged sister, Susan Dahl (defendant). MacGinnis showed Beckwith a will on his computer in which MacGinnis left his substantial estate to Beckwith and Dahl in equal shares. MacGinnis never executed the will. After MacGinnis was admitted to a hospital in poor health, he asked Beckwith to print the will so that he could sign it. When Beckwith could not locate the will, MacGinnis asked him to create a new one. Using a form, Beckwith created a will by which MacGinnis divided his estate equally between Beckwith and Dahl. Beckwith e-mailed a copy of the will to Dahl, who told Beckwith not to give the will to MacGinnis; she would have an attorney draft trust documents within a couple of days instead. Two days later, MacGinnis underwent surgery. As a family member, Dahl was informed that the surgery was life-threatening. Beckwith was not similarly informed, either by the hospital or Dahl. MacGinnis’s condition worsened after surgery, and Dahl removed him from life support. MacGinnis died intestate. Dahl opened probate and applied to be the administrator of MacGinnis’s estate. Over the next six months, Dahl repeatedly ignored Beckwith’s requests for information about the proceedings, which included statements indicating Beckwith’s expectation that MacGinnis’s estate would be distributed to Beckwith and Dahl equally. Eventually, Dahl told Beckwith that MacGinnis’s entire estate would go to her. The probate judge ruled that Beckwith had no standing to oppose distribution of the estate. Beckwith filed an independent, civil complaint against Dahl, alleging intentional interference with an expected inheritance (IIEI). The trial court sustained Dahl’s demurrer to Beckwith’s complaint on the ground that California law did not recognize IIEI claims. Beckwith appealed.
Rule of Law
Holding and Reasoning (O’Leary, J.)
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