Estate of: James W. Porter, Jr., Appeal of: Hickman, L.

Superior Court of Pennsylvania·Decided August 6, 2026·No. 1156 WDA 2025·Unpublished·Bowes

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ESTATE OF: JAMES W. PORTER, JR., : IN THE SUPERIOR COURT OF DECEASED : PENNSYLVANIA :

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APPEAL OF: LYNN MARIE HICKMAN :

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: No. 1156 WDA 2025

Appeal from the Order Entered August 21, 2025 In the Court of Common Pleas of Allegheny County Orphans' Court at No(s): CP-02-OC-0003532-2024

BEFORE: BOWES, J., OLSON, J., and BENDER, P.J.E. MEMORANDUM BY BOWES, J.: FILED: AUGUST 6, 2026 Lynn Marie Hickman (“Daughter”) appeals from the order revoking the letters testamentary that had been issued to Daughter based upon the will executed by her late father, James W. Porter, Jr. (“Decedent”) in 1996, and instead permitted James W. Porter, III (“Son”) to submit Decedent’s pour- over will from 2019, with Son to be named as executor. We remand with instructions for the orphans’ court to prepare a supplemental opinion addressing Daughter’s issues.

By way of background, Decedent died on April 1, 2024, and was survived by his two adult children, Daughter and Son. As summarized by the orphans’ court, “the two children of Decedent have opposing viewpoints as to: probate of [his] wills of 1996 and 2019; amendments to Decedent’s revocable trust during his lifetime; and a deed transferring [Decedent]’s home.” Orphans’ Court Opinion, 11/18/25, at 1 (cleaned up). Specifically, Decedent and his

wife, Alberta B. Porter (“Mother”), executed a will in 1996 (“1996 Will”), which was admitted to probate by Daughter following Decedent’s death. Pursuant to the terms of the 1996 Will, Daughter was issued letters testamentary and named executrix of Father’s estate. The estate consisted solely of Decedent’s residence, located at 120 Dashwood Drive in Penn Hills, Pennsylvania (“the Property”).

Relevantly, after the 1996 Will, Decedent transferred the Property to a revocable living trust in the name of himself and Mother (“the Trust”). Michael A. Nahas, Esquire, assisted with the creation and execution of that instrument in September of 2018. Relevantly, the Trust named the parents as co-trustees and the children as successor trustees. It further designated that the Property would pass equally to Daughter and Son, who were both present when the Trust was signed.

Thereafter, Mother became bedridden and Son assumed caretaking responsibilities for his parents. At the time, Daughter worked full-time and Son was unemployed. On October 15, 2019, the parents amended the Trust (“First Amendment”) and Decedent executed a pour-over will (“2019 Will”). Specifically, the First Amendment designated Son as the first successor trustee and Daughter as the second successor trustee, but still distributed the Property equally to Daughter and Son. The 2019 Will provided that “if something has to go to probate, just follow the terms of what the [T]rust says as far as the beneficiaries.” N.T. Hearing, 4/30/25, at 8. It also revoked the 1996 Will as to Decedent and appointed Son as the executor.

Attorney Nahas drafted both October 15, 2019 documents and served as the notary, while Rosella Johnson and Susan Darocy signed as witnesses to the parents’ signatures. Decedent signed the documents in their presence. Attorney Nahas brought the First Amendment to Mother’s bedroom to sign. The witnesses did not follow him to her bedroom to visibly witness her signing, but attested by their signatures that she had signed. Attorney Nahas and Ms. Darocy did not perceive any issues regarding Decedent’s ability to comprehend what was happening that day. Id. at 10, 28-29. Notably, Son secured the witnesses and was present on October 15, 2019, whereas Daughter was unaware of the 2019 Will or First Amendment.

The Trust was amended by Decedent again in May of 2020 (“Second Amendment”), without the involvement of Attorney Nahas. Although it is stated backwards in terms of the original and new versions of the Trust, it appears that the Second Amendment purported to alter the Trust to allow the Property to pass directly to Son upon the parents’ deaths. Mother died in December of that year and Son moved in with Decedent. On October 5, 2023, Decedent, as trustee for the Trust, conveyed title to the Property to Son. As with the 2019 documents, Daughter was not apprised at the time of execution of the Second Amendment or 2023 transfer.

On August 27, 2024, while administering Decedent’s estate pursuant to the 1996 Will, Daughter filed a petition to void the 2023 transfer of the Property to Son. In response to a rule to show cause why he should not return the Property to the estate, Son filed preliminary objections to Daughter’s

standing and a new rule to show cause why the 2019 Will should not be admitted to probate and Son be appointed executor.

Daughter amended her petition, alleging that Decedent lacked the capacity to amend the Trust in 2019 and 2020, and that Son had exerted undue influence in securing the transfer of the Property to himself in 2023. Once again, Son lodged preliminary objections to Daughter’s standing and claimed that Daughter had failed to supply sufficient facts for him to address the new allegations. After Daughter responded, the court issued Daughter a rule to show cause why the 1996 Will should not be revoked, the 2019 Will be admitted to probate instead, and letters testamentary be granted to Son so he could be named executor. Daughter replied with additional arguments about the amendments to the Trust.

The court held a hearing on April 30, 2025, at which it heard testimony from Son, Attorney Nahas, Ms. Darocy, Ms. Johnson, and Daughter. Son put forth the 2019 Will, the validity of which Daughter contested. According to Son, Decedent executed the 2019 Will, as well as the First and Second Amendments, based upon the disproportionate level of attention and care between Son and Daughter towards the parents between 2019 and 2020. Son testified that he moved in with Decedent in 2020 so Decedent would not be alone after Mother died, and because Decedent needed help with cooking and minor physical ailments. Daughter asserted that Decedent began to show signs of dementia around 2022. Nevertheless, she agreed that he did not exhibit any cognitive issues in 2019. Id. at 91. Son acknowledged that

Decedent’s medical records indicated he had symptoms of dementia, but contested Daughter’s averment that Decedent suffered from that condition.

In closing arguments, Daughter averred that Son had violated his fiduciary duties and impermissibly executed the Second Amendment without notifying Daughter. Id. at 103-04. Furthermore, she argued that Son did not establish the validity of the 2019 Will so as to shift the burden to Daughter to assert undue influence. Id. at 105. The parties submitted proposed findings of fact and conclusions of law after the hearing.1 On August 21, 2025, the court entered the order sub judice, which found the 2019 Will valid, revoked the letters testamentary issued to Daughter based upon the now-revoked 1996 Will, and held that Son could submit the 2019 Will to probate and seek to be sworn in as executor.

Daughter filed a motion for reconsideration, challenging the validity of the First Amendment, 2019 Will, Second Amendment, and 2023 transfer. She further contended that the Property was not subject to probate but rather should be distributed pursuant to the initial terms of the Trust with a surcharge

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Estate of: James W. Porter, Jr., Appeal of: Hickman, L., (Pa. Ct. App. 2026).

Estate of: James W. Porter, Jr., Appeal of: Hickman, L. (Estate of: James W. Porter, Jr., Appeal of: Hickman, L.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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