In Re: Estate of Randolph Benedict Curvan

CourtCourt of Appeals of Georgia
DecidedJune 5, 2025
DocketA25A0310
StatusPublished

This text of In Re: Estate of Randolph Benedict Curvan (In Re: Estate of Randolph Benedict Curvan) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia 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 Randolph Benedict Curvan, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MCFADDEN, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 5, 2025

In the Court of Appeals of Georgia A25A0310. IN RE: ESTATE OF RANDOLPH BENEDICT CURVAN, DECEASED.

HODGES, Judge.

In the second appearance of this case in this Court, Sharon Lavant appeals pro

se an order of the Probate Court of Henry County admitting Randolph Benedict

Curvan’s July 31, 2019 will to probate in solemn form. In the order under appeal, the

probate court noted that it conducted a bench trial on November 7, 2023. However,

no transcript is included in the record on appeal, and Lavant’s notice of appeal states

that, “[b]ecause there are no transcripts of the proceedings in the trial court, none will

be filed for inclusion in the record on appeal.” The lack of a transcript substantially

limits our appellate review and, therefore, we affirm for the following reasons. Generally, “[w]hen a probate court’s findings in a nonjury trial are supported

by any evidence, they must be affirmed on appeal.” O’Callaghan v. Samples, 354 Ga.

App. 42 (1) (840 SE2d 139) (2020). So viewed, the record, such as it is, demonstrates

that Randolph Benedict Curvan (“Curvan”) died testate on February 27, 2020. At the

time of his death, Curvan was married to, but separated from, Cheryl Martina Curvan;

had two adult children, Charmaine Curvan-Lawes and Randolph Andrew Curvan; and

was living with Lavant.1 See In re Estate of Curvan, 362 Ga. App. 665, n. 1 (870 SE2d

1) (2022) (“Curvan I”). In Curvan I, we determined that

in May 2020, [Lavant] filed a petition to probate the [July 31, 2019] Will in solemn form. The Will referenced a trust instrument known as The Randolph Benedict Curvan Living Trust (the “Trust”) and provided that the executor of the Will “shall be the then-acting [t]rustee or [t]rustees” of the Trust. The Will also provided that, after the payment of estate expenses, the remainder of the estate would be given to the trustee to be added to the principal of the Trust and to be held, administered, and distributed under the terms of the Trust. According to Caveators, [Lavant] was the trustee of the Trust, which provided that [Lavant] would receive the entire estate of Randolph Benedict Curvan (“Decedent”).

1 Together, these relatives eventually filed a caveat to Lavant’s original petition to probate Curvan’s July 31, 2019 will in solemn form (the “Caveators”). 2 Caveators filed a caveat to the petition and asserted, inter alia, that the Will was not the valid last will of Decedent, that the signatures on the Will were not Decedent’s, and that [Lavant] was not fit to serve as executor. Although Caveators stated that a previous will was the true last will of Decedent, no such will was attached to their verified caveat.

In July 2020, [Lavant] sought to obtain temporary letters of administration to allow her to collect and preserve Decedent’s assets. The probate court instead appointed an independent temporary administrator for the sole purpose of collecting and preserving Decedent’s assets until a permanent personal representative was appointed.

[Lavant] subsequently filed a motion for summary judgment based on her May 2020 petition to probate the Will. In her motion, [Lavant] sought a ruling that the Will was Decedent’s last true will and recognition that she was Decedent’s spouse. Caveators opposed the motion on all grounds.

After filing her motion for summary judgment, [Lavant] filed a petition to probate a different Last Will and Testament of Randolph B. Curvan dated January 5, 2019. The January 2019 [W]ill provided that, after the payment of all expenses, the remainder of Decedent’s estate would be held in trust for [Lavant] for her lifetime, that [Lavant] would be the sole trustee of the Trust, and that payments would be made to [Lavant] at her discretion. In addition, on [Lavant]’s death, the remainder of Decedent’s

3 estate would be distributed to his children, Charmaine Curvan-Lawes and Randolph A. Curvan. In her petition to probate this will, [Lavant] acknowledged that another purported will of Decedent was pending in the same court. Caveators also filed a caveat to that petition.

Without addressing the petition to probate the January 2019 [W]ill, the probate court granted [Lavant]’s motion for summary judgment as to the validity of the Will and admitted it as proven in solemn form. The probate court denied [Lavant]’s motion to the extent she sought recognition as Decedent’s spouse. In addition, the court concluded that [Lavant] could not serve as executor because of a conflict of interest and appointed the independent temporary administrator as executor of the estate.

(Footnotes omitted.) Id. at 666-667. We reversed, concluding that Lavant’s competing

petitions to probate two different wills “created a factual question that must be

resolved by the factfinder.” Id. at 667.

On remand, the Caveators filed a motion for summary judgment in June 2022,

asserting that Curvan’s July 31, 2019 will was void because Lavant executed the will

as both a beneficiary and a witness. The probate court concluded that “an issue of fact

remains regarding whether the will dated July 31, 2019 is the will of the Decedent”

and denied the Caveators’ summary judgment motion in February 2023.

4 Based upon the evidence adduced at the ensuing bench trial in November 2023,

the probate court entered a June 2024 order that concluded Curvan’s July 31, 2019

will was valid and admitted it to probate in solemn form, but further concluded that

Lavant had a conflict of interest and could not serve as the estate’s personal

representative. As a result, the court appointed an independent administrator for the

estate. This appeal followed.

1. At the outset, we note that Lavant’s appellant’s brief does not contain an

enumeration of errors. See OCGA § 5-6-40 (“The appellant . . . shall file with the

clerk of the appellate court . . . an enumeration of the errors which shall set out

separately each error relied upon. The enumeration shall be concise and need not set

out or refer to portions of the record on appeal. . . . The appellate court, by rule, may

permit the enumeration to be made a part of the brief.”); Court of Appeals Rule 25 (a)

(4) (“At a minimum, the appellant’s brief must include . . . [t]he enumeration of

errors, which must identify separately and concisely each allegedly erroneous ruling

the appellant relies on as a basis for reversal of the judgment on appeal. See OCGA §

5-6-40.”).

[P]roceeding pro se does not relieve [Lavant] of [her] obligation to comply with the rules of this [C]ourt. Our requirements as to the form

5 of appellate briefs were created, not to provide an obstacle, but to aid parties in presenting their arguments in a manner most likely to be fully and efficiently comprehended by this [C]ourt.

(Citation and punctuation omitted.) Newsome v. Graham, 365 Ga. App. 202, 202-203

(2) (877 SE2d 371) (2022). And while the lack of an enumeration of errors may not

necessarily result in the dismissal of Lavant’s appeal,2 it needlessly hinders our review.

See Clark v. Rau, 338 Ga. App. 251, 253 (1) (789 SE2d 399) (2016) (physical precedent

only). “Nevertheless, we will address [Lavant’s] arguments, insofar as we are able to

ascertain them from her brief.” (Citation and punctuation omitted.) Morman-Johnson

v.

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In Re: Estate of Randolph Benedict Curvan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-randolph-benedict-curvan-gactapp-2025.