Fiel v. Hoffman

Ben Novack, decedent, was murdered by his wife, Narcy Novack. Narcy also murdered Ben’s mother. Ben’s will stated that Narcy’s daughter and two grandsons from her prior marriage would inherit Ben’s entire estate if both Narcy and Ben’s mother predeceased Ben. There was no blood relationship between Ben and his stepdaughter and stepgrandsons. Narcy’s relationship with her daughter and grandsons was strained. After Narcy submitted Ben’s will for probate, the probate court ruled that Florida’s slayer statute barred Narcy from inheriting Ben’s estate and, therefore, that Narcy’s daughter and grandsons were Ben’s sole heirs. Ben’s cousins, Meredith and Lisa Fiel (the cousins) (plaintiffs), filed a complaint to invalidate Ben’s will and instead enforce an earlier will that had left Ben’s estate to Meredith and Lisa. The cousins argued that (1) Narcy used physical violence to unduly influence Ben into executing a will benefitting her and her family and (2) the slayer statute barred inheritance by Ben’s stepdaughter and stepgrandsons because they were not Ben’s blood relatives and because Narcy could benefit from the inheritance through them. Douglas Hoffman (defendant), the personal representative of Ben’s estate, moved to dismiss the cousin’s complaint, and the court complied, holding that (1) even if Narcy had unduly influenced Ben, that would only invalidate bequests to Narcy, not to the stepdaughter and stepgrandsons; and (2) the slayer statute did not prohibit the stepdaughter and stepgrandsons from inheriting under Ben’s will. The cousins appealed.