Buffenbarger v. Estate of Meyer

2023 Ohio 2760, 222 N.E.3d 55
CourtOhio Court of Appeals
DecidedJuly 26, 2023
Docket22CA10
StatusPublished
Cited by3 cases

This text of 2023 Ohio 2760 (Buffenbarger v. Estate of Meyer) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Buffenbarger v. Estate of Meyer, 2023 Ohio 2760, 222 N.E.3d 55 (Ohio Ct. App. 2023).

Opinion

[Cite as Buffenbarger v. Estate of Meyer, 2023-Ohio-2760.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT HIGHLAND COUNTY

ROBERT THOMAS BUFFENBARGER, ET AL., :

Plaintiffs-Appellants, : Case No. 22CA10

v. : NUNC PRO TUNC ESTATE OF WILLIAM AUGUSTUS : DECISION & JUDGMENT ENTRY MEYER, ET AL., : Defendants-Appellees.

_______________________________________________________________

APPEARANCES:

Donald A. Cox, Orient, Ohio, for appellants.

Joshua Gunsher and Michael P. Richardson, Fairfield, Ohio, for appellees. ________________________________________________________________ CIVIL APPEAL FROM PROBATE COURT DATE JOURNALIZED:7-26-23 ABELE, J.

{¶1} This is an appeal from a Highland County Common Pleas

Court, Probate Division, summary judgment in favor of Kurt A.

Buffenbarger (Kurt) and James T. Buffenbarger (Tad)1 as

coexecutors of the estate of William Augustus Meyer, defendants

The depositions sometimes refer to James T. Buffenbarger as Thad. Throughout this opinion, we have chosen the nickname that appears in appellees’ brief, Tad. 2 HIGHLAND, 22CA10

below and appellees herein. Robert Thomas Buffenbarger (Tom), Bruce Timothy Buffenbarger

(Tim), and additional parties,2 plaintiffs below and appellants

herein, assign the following error for review:

“DID THE TRIAL COURT CORRECTLY GRANT THE SUMMARY JUDGMENT IN THE COURT BELOW BASED UPON THE PROPER STANDARD OF REVIEW SET FORTH IN OHIO CIVIL RULE 56?”

{¶3} William Augustus Meyer, the decedent, was an elderly

man who never married or had children. Two of the decedent’s

nephews who lived in the area, Kurt and Tad, along with Tad’s

wife, Carla Buffenbarger, helped care for him until his death on

November 8, 2020.

{¶4} On March 11, 2021, the decedent’s last will and

testament was filed in probate court. The will bequeathed

various amounts of money to some of the decedent’s relatives and

to charitable organizations. Each of the following nieces and

nephews received $5,000: Linda Meyer, Vicky Meyer, Kurt Warner,

Timothy Buffenbarger, Sally Sagel, and Tom Buffenbarger.

Another niece, Tisha Golden, received $20,000. The will left

the primary residence to Kurt and the residual estate to Kurt

and Tad. The will also appointed Kurt and Tad as the estate’s

2 The additional plaintiffs listed in the complaint are Vicki Anne Gierhart, Linda Meyer, Sara Jane Sagel, Kathy Dye Edwards, and William Rawers. 4 HIGHLAND, 22CA10

personal representatives. Additionally, the will recites that

the decedent signed the document on October 31, 2020, before two

disinterested witnesses, contains a “certificate of

acknowledgment” to indicate that on October 31, 2020 the

decedent acknowledged the will before Michelle Nephew, a notary,

and each page of the will contains the decedent’s signature.

{¶5} On May 4, 2021, appellants filed a will-contest

complaint and alleged they are estate beneficiaries and the will

admitted to probate is invalid. Appellants claimed, inter alia,

that the decedent lacked testamentary capacity, the will was not

properly witnessed, the “will is the product of undue influence,

manipulation, deceit, and coercion,” and the “will is a fraud

and a fake.”

{¶6} On July 22, 2022, appellees filed a summary judgment

motion and asserted that appellants have no evidence to create a

genuine issue of material fact as to validity of the will. In

response, appellants argued that genuine issues of material fact

remain because of witness credibility, the decedent’s

testamentary capacity, whether the will had been properly

witnessed and whether Kurt unduly influenced the decedent. To

support their argument, appellants relied upon the depositions

that had been filed in the case. {¶7} In reply, appellees asserted that appellants did not

produce competent evidence to show that genuine issues of

material fact remain for a factfinder to resolve. In

particular, they pointed out that because none of the appellants

have personal knowledge of the circumstances that surrounded the

preparation and execution of the will, they are not competent to

testify to the decedent’s testamentary capacity, to the will’s

execution, or whether the will is the product of undue

influence.

{¶8} A review of the depositions reveal that, before the

decedent’s death, Kurt explained he had some discussions with

him about a will. The decedent was familiar with radio-talk-

show host Dave Ramsey and “his will kit.” Kurt told the

decedent that “he needed something like that.” Kurt also found

what appeared to be a handwritten will worksheet in the

decedent’s house and brought it to the decedent, who at that

point resided in a medical facility. Kurt asked the decedent if

the worksheet contained the provisions the decedent wanted to

include in his will, and he confirmed that it did. Kurt then

used the will worksheet to prepare the will the decedent signed.

{¶9} Kurt took the will to the decedent in the hospital and

he read the will. Kurt then left the room before the decedent 6 HIGHLAND, 22CA10

signed the will. Approximately ten minutes later, Kurt returned

to the room and picked up the signed will.

{¶10} Tamson Connelly, a registered nurse, witnessed the

decedent sign the will. She stated that the other witness,

Candace Schnee, also was present in the room. Connelly thinks

that a notary also may have been in the room, but she does not

specifically recall whether a notary actually was present.

Connelly did not remember precisely how long she was in the

room, the time of day she witnessed the signature, or anything

specific about the decedent. Also, Connelly does not know if

the decedent read the will. She explained, however, that she

has witnessed wills in the past and when she does so, she

ensures that the person is the “right patient” by asking for the

person’s name and checking the person’s arm band. As part of

her process, Connelly would ask the person if he or she was

aware that she had been asked to witness their signature and she

“would stand there and watch him sign his name before I would

sign my name that I saw him sign his name to the document.”

Connelly stated that, if she saw anything that led her to

believe that the person was being pressured, she would say

something. {¶11} Candace Schnee, a nurse practitioner, also witnessed

the decedent sign the will. Schnee stated that she, Connelly

and a notary were all present in the room when the decedent

signed the will, but she does not recall specific people in the

room. Schnee indicated that the decedent was in the bed and the

will may have been on a bedside table or a clipboard, but she

does not recall. She also does not know if the decedent read

the will. Schnee stated that she had not witnessed a will

signature in the past, but she had witnessed other legal

documents. She explained that, before she would sign a document

as a witness, she would assess the room and the patient to “read

everything going on in the room” and would engage in

conversation to ensure that the person understood “where they

are, who they are.” Schnee stated that she would not sign a

document if she felt that something was not right, or if she

thought that the person signing did not know what the person was

doing.

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 2760, 222 N.E.3d 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buffenbarger-v-estate-of-meyer-ohioctapp-2023.