Estate of Hand

73 N.E.3d 880 (2016)

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Estate of Hand

Ohio Court of Appeals
73 N.E.3d 880 (2016)

Facts

After Eric Anthony Hand died, his wife, Natalie Hand (plaintiff) searched for a will. In a box of love letters, Natalie found a three-page, three paragraph letter. The first two paragraphs of the letter professed Eric’s love for Natalie using a style and tone consistent with the couple’s other love letters. In the third paragraph of the letter, Eric stated, “As my last will and testament, I appoint you the primary beneficiary of all I have and all I have worked for.” Eric signed the letter with his full name. After he wrote the letter, Eric told Natalie that he intended to legally create a will in the future. At a hearing, Natalie testified that the letter was Eric’s way of expressing his love for her and assuring her of the strength and stability of their relationship. The probate court denied Natalie’s application to admit the will to probate, and Natalie appealed.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

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Casebooks

Wills, Trusts, and Estates

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