In re Estate of Joseph

2025 Ohio 858
CourtOhio Court of Appeals
DecidedMarch 14, 2025
DocketC-240150
StatusPublished
Cited by1 cases

This text of 2025 Ohio 858 (In re Estate of Joseph) 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
In re Estate of Joseph, 2025 Ohio 858 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Estate of Joseph, 2025-Ohio-858.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

IN RE: ESTATE OF ALICE M JOSEPH : APPEAL NO. C-240150 TRIAL NO. 2022001512 :

: OPINION

Appeal From: Hamilton County Court of Common Pleas, Probate Division

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: March 14, 2025

Bill Baker, pro se. OHIO FIRST DISTRICT COURT OF APPEALS

BOCK, Judge.

{¶1} In this appeal, appellant Bill Baker challenges the probate court’s

decision to deny his motion to admit a lost will to probate. But Bill did not file a hearing

transcript, preventing us from reaching the merits of his argument. Consequently, we

overrule his assignment of error and affirm the probate court’s judgment.

I. Factual and Procedural History

{¶2} Alice M. Joseph passed away in February 2022, leaving behind four

sons, Bill, Bobby, Tony, and Jerry Baker, and three grandchildren who survived Ms.

Joseph’s fifth child.

{¶3} In April 2022, Bill filed a pro se application to relieve the estate from

administration. Bill indicated that Ms. Joseph had died without a will and with less

than $35,000 in assets. On a separate form, he identified $5,400 held in a Fifth Third

Bank account. The probate court appointed Bill commissioner of the estate, and he

distributed half of that $5,400 to himself and the other half to his brother Bobby.

{¶4} Shortly thereafter, Bill, now represented by counsel, filed a second

application for authority to administer the estate, which consisted of real property

worth $155,000. Only this time, Bill omitted Jerry from the list of Ms. Joseph’s

surviving children. Bill, Bobby, and Tony signed the waiver-of-notice form. The

probate court appointed Bill administrator. That same day, Bill filed an inventory of

assets, identifying real property worth $94,510. Bill also filed a “waiver of notice of

hearing on inventory” form that bore Bobby’s and Tony’s signatures, but not Jerry’s.

{¶5} The next month, Bobby and Jerry filed separate requests for a status

conference. Both Bobby and Jerry explained that they “did not know about [the]

Probate case for mother Alice Joseph, case 2022001512.” They also alleged that they

“did not sign any documents or any waivers.” Jerry added that he was “excluded from

2 OHIO FIRST DISTRICT COURT OF APPEALS

the amended next of kin form.”

{¶6} Following a status conference, Bill supplemented the next-of-kin form

and identified the seven heirs to the estate. In December 2022, the magistrate issued

an order of judgment against Bill and Bobby, explaining that Bill incorrectly divided

the $5,041.95 account between only Bill and Bobby. That account should have been

divided between all seven heirs, with each child of Ms. Joseph receiving one-fifth of

the account, and each grandchild receiving one-fifteenth of the account.

{¶7} In January 2024, Bill applied to probate a “lost, spoliated or destroyed

will.” Bill claimed that in December 2021, Ms. Joseph signed a will that was attested

and subscribed by Bill, Alicia, and Trudy Baker, and witnessed by Philip Rigsby. Bill

explained that “Brother got will Bob and Jerry out of house [sic].” According to the

“lost will,” Ms. Joseph bestowed the interest in her real property “under the attached

Schedule-Beneficiary Designations.” Yet, there was no “Schedule-Beneficiary

Designations” document attached to the “lost will.”

{¶8} Following a hearing, the probate court denied Bill’s request to admit

the “lost will.” The probate court found that Bill had failed to satisfy his burden, citing

“improprieties in the estate administration,” irregularities on the lost will including

“the disparate appearance of the signature page,” “the differences between the

signatures of [Ms. Joseph]” on the lost will and the beneficiary schedule produced by

Bill at the hearing, and the credibility of the witnesses.

{¶9} The probate court noted that the copy of the purported will “has several

irregularities on its face,” including the lack of any referenced schedules and the fact

that “the signatures of the decedent and the witnesses appear on a page with no other

provisions on it and the typewritten font on the signature page appears to be different

than that in the rest of the document.” The probate court cited Jerry’s testimony that

3 OHIO FIRST DISTRICT COURT OF APPEALS

the will included incorrect birth dates of two of Ms. Joseph’s children.

{¶10} According to the probate court, Bill “produced a second document . . .

Exhibit B . . . which was also allegedly prepared and signed on the same day as the

alleged last will.” That second document states that Ms. Joseph made Bill the

“beneficiary of all my belongings . . . and my house and property.” The probate court

pointed out that Ms. Joseph’s signature on Exhibit B is “markedly different” from her

signature on the purported will, and the signatures of Gertrude and Alicia Baker “also

appear to be different.” And “Jerry Baker testified that the signature on Exhibit B did

not appear to be decedent’s signature.”

II. Analysis

{¶11} On appeal, Bill challenges the probate court’s decision to deny the

admission of the “lost will” in one assignment of error. Bill maintains that his mother

intentionally chose him to continue living in her house, where he has lived for 34 years,

and which holds sentimental value for him. He explains that his mother severed her

relationship with Jerry before she passed.

{¶12} As an initial matter, Bill failed to file a transcript of the hearing or

marshal a legal argument in support of his request to reverse the probate court’s

decision. As the appealing party, Bill “bears the burden to provide legal and factual

support for arguments that []he brings before this court, as prescribed by the Ohio

Rules of Appellate Procedure and our local appellate rules.” See Guthrie v. Guthrie,

2024-Ohio-5581, ¶ 12 (1st Dist.), citing App.R. 16(A)(7) and Loc.R. 16.1(A)(3)(c)-(4).

We have repeatedly cautioned appellants that it is their responsibility “to explain to

us, with citations to authority and the record, how the trial court erred.” Olthaus v.

Niesen, 2023-Ohio-4710, ¶ 9 (1st Dist.). A party’s “‘failure to develop an authority-

based argument provides sufficient grounds to’ reject h[er] appeal and to affirm the

4 OHIO FIRST DISTRICT COURT OF APPEALS

judgment of the trial court.” Niesen at ¶ 11, quoting Ohiotelnet.com, Inc. v.

Windstream Ohio, Inc., 2013-Ohio-4721, ¶ 16-17.

{¶13} In support of his argument, Bill cites R.C. 5808.11. But R.C. 5808.11

provides, “A trustee shall take reasonable steps to enforce claims of the trust and to

defend claims against the trust.” The statute is inapplicable to this case.

{¶14} Rather, admitting a lost will to probate is governed by R.C. 2107.26. A

probate court “shall admit” a lost will to probate if (1) the proponent of the lost will

establishes, by clear and convincing evidence, the contents of the will and that the lost

“will was executed with the formalities required at the time of execution,” and (2) no

opposing party “establishes by a preponderance of the evidence that the testator had

revoked the will.” R.C. 2107.26(A) and (B). A hearing to admit a lost will “‘is no idle

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 858, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-joseph-ohioctapp-2025.