In re Estate of Baker

2023 IL App (4th) 221033-U
CourtAppellate Court of Illinois
DecidedSeptember 14, 2023
Docket4-22-1033
StatusUnpublished

This text of 2023 IL App (4th) 221033-U (In re Estate of Baker) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Estate of Baker, 2023 IL App (4th) 221033-U (Ill. Ct. App. 2023).

Opinion

NOTICE 2023 IL App (4th) 221033-U This Order was filed under FILED NO. 4-22-1033 September 14, 2023 Supreme Court Rule 23 and is Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

In re Estate of JAMES A. BAKER, Deceased ) Appeal from the ) Circuit Court of (Natosha R. Edwards, ) Ford County Petitioner-Appellant, ) No. 20P31 v. ) Randal R. Baker, ) Honorable Respondent-Appellee). ) Matthew J. Fitton, ) Judge Presiding.

PRESIDING JUSTICE DeARMOND delivered the judgment of the court. Justices Turner and Cavanagh concurred in the judgment.

ORDER ¶1 Held: The appellate court reversed and remanded with directions, finding (1) petitioner’s allegations were not res judicata and gave rise to inferences that decedent lacked testamentary capacity and (2) the circuit court abused its discretion when it dismissed, with prejudice, petitioner’s complaint without first allowing petitioner leave to amend.

¶2 James A. Baker died in October 2020, leaving a will which named his daughter,

petitioner Natosha R. Edwards, and brother, respondent Randal R. Baker, as beneficiaries of his

estate. In May 2021, Natosha filed a petition to contest the validity of James’s will. Randal, as

executor of James’s estate, filed a combined motion under section 2-619.1 of the Code of Civil

Procedure (Code) (735 ILCS 5/2-619.1 (West 2020)), asking for the petition to be dismissed. In

January 2022, the circuit court dismissed the petition with prejudice. ¶3 Natosha appeals, arguing the circuit court (1) erred in granting Randal’s motion to

dismiss and (2) abused its discretion by dismissing her petition with prejudice without first

allowing her an opportunity to file an amended petition. We reverse and remand with directions.

¶4 I. BACKGROUND

¶5 In November 2017, James executed a last will and testament which bequeathed

seven tracts of land, James’s entire stock in Baker Scrap Inc., and all equipment belonging to

Baker Scrap Inc. to Randal. The will left the entire residue of the estate to Natosha and provided

that, if Natosha did not survive James—which she did—the residue of James’s estate would go

to James’s son, Joshua Baker. In December 2020, Randal filed a petition for probate of the will

and for letters testamentary. The petition named Joshua and Natosha as heirs. As legatees, the

petition named Randal and Natosha.

¶6 In January 2021, Natosha filed a petition to require formal proof of James’s will

in the manner required by section 6-21 of the Probate Act of 1975 (Probate Act) (755 ILCS

5/6-21 (West 2020)). According to a bystander’s report (of hearings conducted by the circuit

court on April 1 and May 6, 2021) filed by the parties, Kyra Kennedy testified she witnessed the

signing of the will in her office, and at the time of its execution, James appeared to know what he

was signing and to be of sound mind. Lisa Stahl also testified she witnessed the signing of the

will, and she stated James signed the will voluntarily and appeared to be of sound mind. Randal

testified he was present when James signed the will. Randal averred James seemed to be of

sound mind and memory, and it appeared to Randal that James knew he was signing his last will

and testament. Finally, although unable to procure the testimony of the final witness to James’s

will, Randal argued the will “had a self-authentication clause with a notary signature and

-2- therefore the technical requirements to the execution of the [w]ill were met.” The court agreed

and subsequently admitted the will to probate.

¶7 On May 26, 2021, Natosha filed a petition to contest the validity of James’s will.

The petition alleged James lacked testamentary capacity because, prior to his stroke in

September 2016, James told Natosha he had executed a will and was leaving his entire estate to

his children. According to the petition, James was diagnosed with dementia following his stroke

and was unable to feed, bathe, clothe himself, or use the bathroom independently. The petition

also stated James urinated in his dryer and placed bowel movements on plates from which he

was eating multiple times. The petition further alleged James was unable to hold a conversation,

mumbled to himself constantly, and mistook Natosha for his ex-wife. Finally, the petition

claimed James’s “ability to understand questions, or to articulate wishes or directions, did not

improve” from the time of his stroke until his death in October 2020.

¶8 In July 2021, Randal filed a combined motion pursuant to section 2-619.1 of the

Code seeking to dismiss Natosha’s petition on the grounds it failed to state a claim upon which

relief could be granted and was barred by the doctrine of res judicata. Specifically, under section

2-619(a)(4) of the Code (735 ILCS 5/2-619(a)(4) (West 2020)), Randal contended the circuit

court’s admission of James’s will to probate “in essence *** ruled that [James’s] *** [w]ill was

valid,” and therefore, Natosha’s will contest was subject to dismissal as being barred by a prior

judgment. Pursuant to section 2-615 of the Code (735 ILCS 5/2-615 (West 2020)), Randal

asserted Natosha’s allegations were “merely general conclusions” and insufficient to allege

James lacked testamentary capacity on the day the will was signed.

¶9 In January 2022, the circuit court entered an order granting Randal’s motion to

dismiss Natosha’s petition to contest the validity of James’s will pursuant to sections 2-615 and

-3- 2-619(a)(4) of the Code, with prejudice. Under section 2-615, the court noted conclusions of fact

were insufficient to state a cause of action regardless of whether they generally inform a party of

the nature of the claim. Thus, the court found Natosha’s petition stated general conclusions as to

James’s mental unsoundness because it failed to “set out specific times, dates[,] or places of the

various incidents alleged.” Pursuant to section 2-619(a)(4), the court found the arguments

“regarding [James’s] *** cognitive well-being and understanding” raised in Natosha’s petition

were res judicata because the court previously heard evidence related to James’s state of mind

during the admission proceedings.

¶ 10 In February 2022, Natosha filed a motion to reconsider and requested leave to file

an amended petition with a proposed amendment, alleging James was diagnosed with dementia

and major depressive disorder one day after signing the November 2017 will. The circuit court

denied Natosha’s motion.

¶ 11 This appeal followed.

¶ 12 II. ANALYSIS

¶ 13 On appeal, Natosha argues the circuit court (1) erred in granting Randal’s motion

to dismiss and (2) abused its discretion by dismissing her petition with prejudice without first

allowing her an opportunity to file an amended petition. We address each of Natosha’s

arguments in turn.

¶ 14 A. Section 2-619.1 Motions to Dismiss

¶ 15 Section 2-619.1 of the Code permits a litigant to combine a section 2-615 motion

to dismiss with respect to the pleadings and a section 2-619 motion for involuntary dismissal into

a single pleading. 735 ILCS 5/2-619.1 (West 2020); Walworth Investments-LG, LLC v. Mu

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Bluebook (online)
2023 IL App (4th) 221033-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-baker-illappct-2023.