In re Estate of Straub

Ohio Court of Appeals·Decided August 4, 2026·No. CA2025-09-107·Published

Opinion

[Cite as In re Estate of Straub, 2026-Ohio-3006.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO BUTLER COUNTY

IN RE: :

CASE NO. CA2025-09-107

ESTATE OF JOHN C. STRAUB, JR., :

DECEASED OPINION AND : JUDGMENT ENTRY 8/4/2026

:

:

:

APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS PROBATE DIVISON

Case No. PE23-06-0683

Gunsher Attorneys, Ltd., and Joshua Gunsher and Michael P. Richardson, for appellees. Bolin & Troy L.L.C., and Charles D. Maddox and Cathryn N. Loucas, for appellants.

OPINION

BYRNE, P.J.

{¶ 1} Savannah Ellen Lewis appeals the decision of the Butler County Court of Common Pleas, Probate Division, denying her application to admit to probate the purported will of her grandfather, John C. Straub, Jr. ("Grandfather"). For the reasons

discussed below, we affirm.1 I. Factual and Procedural Background

{¶ 2} Grandfather died in 2023. In 2025, his granddaughter, Lewis, sought to admit Grandfather's durable power of attorney ("POA") to the probate court as his last will and testament. Shortly thereafter, the probate court entered an interlocutory order denying Lewis's application. In so doing, the probate court found that the instrument Lewis offered for probate was "not a will" because it did not "purport to dispose of the decedent's estate." (Underlined text in original.)

{¶ 3} Following the court's interlocutory order, Lewis requested that the probate court hold a hearing on the matter. Lewis made her request pursuant to R.C. 2107.181, which provides that if the probate court denies an application to admit a will to probate, the court must "continue the matter for further hearing," during which "witnesses may be called, subpoenaed, examined, and cross-examined." Upon the conclusion of the hearing, the court shall then either "revoke its interlocutory order . . . and admit it to probate, or enter a final order refusing to probate it."

{¶ 4} The probate court held the requested hearing. At the hearing, Lewis's counsel presented two witnesses: Jonathan Gleisinger and Scott Stoll. Gleisinger testified that he had known Grandfather for 25 years and that he was a witness to the purported will. Stoll testified to the same and indicated that he was a brother-in-law and "really good friend" of Grandfather. He also stated that he was a "witness to a notary for the will/POA" or "whatever it was called" and that he "kn[e]w exactly what [Grandfather] wanted." Stoll further testified that Grandfather "wanted absolutely everything to go to his three grandchildren" and that Grandfather made that "very clear" to him.

1. Pursuant to Loc.R. 6(A), we have sua sponte removed this appeal from the accelerated calendar. See 902 Carp Loveland L.L.C. v. Potts, 2026-Ohio-1313, ¶ 1, fn. 1 (12th Dist.).

{¶ 5} Following the hearing, Lewis filed a motion to reopen or to continue the oral hearing for the "limited purpose" of further examining Gleisinger. The magistrate denied the motion, finding that "there [was] no benefit in affording [Lewis] an opportunity to elicit additional testimony from [Gleisinger]" because "[f]urther testimony would have no bearing on the Court's ultimate decision that the purported Will is a [POA] which terminated upon the decedent's death." The magistrate further stated that the POA could not be "extended or transformed into another instrument thereafter no matter what [Lewis] otherwise wishe[d]."

{¶ 6} Later that same day, the magistrate entered an order denying Lewis's application to admit the purported will to probate. In the magistrate's order, the magistrate recognized that the purported will was titled "Durable Power of Attorney" and that a provision in the instrument "instructed the decedent's appointed Attorney-in-Fact ("Agent") to 'divide all my worldly possessions among my 3 grandchildren who have lived with me their entire life . . . Savannah, Tiffany and Corey will divide everything among them.'"

{¶ 7} In so doing, the magistrate found that "the dispositive provision" in the purported will was the final sentence, which stated that the "Durable Power of Attorney shall remain in effect until my demise or until it is revoked by me through written notification to my Agent." From this provision, the magistrate found that "[i]t [was] clear . . . that all powers and authority conferred on the decedent's Agent by this instrument were to end upon the decedent's death" and that reliance on the POA to "serve as a Will after the decedent's death for the purpose of allocating and dividing the decedent's worldly possessions [was] misplaced."

{¶ 8} Lewis objected to the magistrate's decision. In her objections, Lewis argued that the magistrate erred in denying her application because the "denial was based on

her substantive interpretation of the language contained in the will rather than the formal requirements of the execution of a will as contained in Ohio Revised Code 2107.03." A few weeks later, Lewis filed a supplement to her objections, stating that the "document must be admitted to probate" because it "satisfie[d] all of the essential items . . . in ORC 2107.03."

{¶ 9} On August 11, 2025, the probate court overruled Lewis's objections and affirmed and adopted the magistrate's decision. Lewis subsequently appealed, raising two assignments of error for review. We will address each of Lewis's two assignments of error in turn.

II. Law and Analysis

{¶ 10} Lewis's first assignment of error states:

THE TRIAL COURT ERRED IN DENYING THE APPLICATION TO ADMIT THE DECEDENT'S WILL TO PROBATE PURSUANT TO R.C. 2107.18 WHERE THE WILL FACIALLY COMPLIED WITH ALL EXECUTION FORMALITIES PRESCRIBED BY R.C. 2107.03.

{¶ 11} In support of her first assignment of error, Lewis argues that the probate court erred in denying her application to admit a purported will to probate pursuant to R.C. 2107.18 because R.C. 2107.18 "strictly limits the court's review to confirming the will's facial compliance with execution formalities under R.C. 2107.03" and "preclud[es] a substantive interpretation of the document's contents."

{¶ 12} We disagree with Lewis's argument as it is inconsistent with the plain reading of R.C. 2107.18 and Ohio caselaw.

A. Can a Probate Court Examine the Contents of a Purported Will?

{¶ 13} To begin our analysis, we must start with the text of R.C. 2107.18. The first paragraph of that statute, which is titled "Admission to Probate," provides, in pertinent part, the following:

The probate court shall admit a will to probate if it appears from the face of the will, or if the probate court requires, in its discretion, the testimony of the witnesses to a will and it appears from that testimony, that the execution of the will complies with the law in force at the time of the execution of the will in the jurisdiction in which the testator was physically present when it was executed, with the law in force in this state at the time of the death of the testator, or with the law in force in the jurisdiction in which the testator was domiciled at the time of the testator's death.

(Emphasis added.) R.C. 2107.18.

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