Estate of Dow
New Hampshire Supreme Court
260 A.3d 1 (2021)

- Written by Sean Carroll, JD
Facts
Christopher Dow (plaintiff) was the son of Marie Dow. Marie’s will left her residuary estate to her daughter-in-law Leslie Dow or, if Leslie failed to survive Marie, to Marie’s granddaughter. Christopher was married to Leslie, and the referenced granddaughter was Christopher and Leslie’s child. The will stated that Marie intentionally omitted anyone not named. Christopher was not named in the will. After Marie’s death, Christopher filed a petition in probate court seeking a ruling that he was a pretermitted heir of Marie and was therefore entitled to an intestate share of Marie’s estate. The probate court found that Christopher was not a pretermitted heir. Christopher appealed.
Rule of Law
Issue
Holding and Reasoning (Hantz Marconi, J.)
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