Edward Kowalski, Jr. v. Teri-Ellin K. Finley and the Estate of Edward R. Kowalski, Sr.

CourtCourt of Appeals of Texas
DecidedSeptember 21, 2004
Docket14-03-00715-CV
StatusPublished

This text of Edward Kowalski, Jr. v. Teri-Ellin K. Finley and the Estate of Edward R. Kowalski, Sr. (Edward Kowalski, Jr. v. Teri-Ellin K. Finley and the Estate of Edward R. Kowalski, Sr.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edward Kowalski, Jr. v. Teri-Ellin K. Finley and the Estate of Edward R. Kowalski, Sr., (Tex. Ct. App. 2004).

Opinion

Reversed and Remanded and Memorandum Opinion filed September 21, 2004

Reversed and Remanded and Memorandum Opinion filed September 21, 2004.

In The

Fourteenth Court of Appeals

____________

NO. 14-03-00715-CV

EDWARD R. KOWALSKI, JR., Appellant

V.

TERI-ELLIN K. FINLEY AND THE ESTATE OF EDWARD R. KOWALSKI, SR.,

DECEASED, Appellees

__________________________________________________________________________

On Appeal from the Probate Court No. 2

Harris County, Texas

Trial Court Cause No. 335,669

__________________________________________________________________________

M E M O R A N D U M   O P I N I O N

Appellant Edward R. Kowalski, Jr. (AKowalski@) appeals from an order admitting his father=s will to probate as a muniment of title.  Appellee Teri-Ellin K. Finley (AFinley@) is appellant=s sister and an heir of the testator, Edward R. Kowalski, Sr.  Appellant contends the trial court erred by admitting the will in violation of statutory requirements.  Specifically, he claims (1) he did not receive statutory notice in violation of his due process rights, and (2) Finley failed to prove that she was not in default in failing to probate the will during the four-year period after death.  We reverse and remand.


I.  Factual and Procedural Background

Edward Kowalski, Sr. died on May 8, 1998, survived by his two adult children, Edward Kowalski, Jr. and Teri-Ellin Finley.  On December 20, 2002, more than four years after her father=s death, Finley filed an application to probate her father=s will as a muniment of title.[1]  The devisee under the will, referred to as a Apour-over will,@ is The Edward R. Kowalski, Sr. Revocable Living Trust.

On March 18, 2003, the probate court held a hearing on Finley=s application.  In her sworn proof of death and other facts submitted to the probate court, Finley asserted she served notice on Kowalski by mailing a copy of the application, along with a waiver, by regular mail and certified mail, with return receipt requested.  She stated the certified mail was returned unclaimed.  Finley further averred that she was not in default for failing to probate the will within four years of her father=s death because she was not aware that real property was titled in her father=s name instead of in the name of his revocable trust.[2]  After consideration of Finley=s sworn proof, the court found that Finley was not in default for failing to probate the will within four years of her father=s death and that notice and citation had been given in the manner and for the length of time required by law.  See Tex. Prob. Code ' 89B(a)(3) (Vernon 2003).  The court then signed an order on March 18, 2003, admitting the will to probate as a muniment of title.  See Tex. Prob. Code ' 89C(a) (Vernon 2003).


On April 17, 2003, Kowalski filed a motion for new trial asserting he did not receive legal notice and challenging the proof that Finely was not in default.  The motion was overruled by operation of law, and this appeal followed.  See Tex. Prob. Code Ann. ' 5(g) (Vernon 2003); Huston v. F.D.I.C., 800 S.W.2d 845, 848 (Tex. 1990) (holding probate order is appealable if it finally adjudicates a substantial right).

II.  Proper Notice

In Kowalski=s first issue, he contends the trial court violated his due process rights because he was not given proper notice of the application pursuant to Texas Probate Code section 128B, which requires service of process when a will is probated more than four years after death.  See Tex. Prob. Code Ann. ' 128B (Vernon 2003).[3]  The legislature added section 128B to the Probate Code in 1999.  Act of June 18, 1999, 76th Leg., R.S., ch. 855, ' 2, 1999 Tex. Gen. Laws 3527.  The change in the law applies only to the estate of a person who dies on or after September 1, 1999, the effective date of the act.  Id. ' 13.  An estate of a person who dies before September 1, 1999, is governed by the law in effect on the date of death, and the former law is continued in effect for that purpose.  Id.  In this case, the date of death was May 8, 1998, before the effective date of the act.  Accordingly, the former law applies.[4]

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Edward Kowalski, Jr. v. Teri-Ellin K. Finley and the Estate of Edward R. Kowalski, Sr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-kowalski-jr-v-teri-ellin-k-finley-and-the-e-texapp-2004.