In re the Succession of Vicaro

612 So. 2d 839, 1992 La. App. LEXIS 4217, 1992 WL 410164
CourtLouisiana Court of Appeal
DecidedDecember 23, 1992
DocketNo. CA 92 0483
StatusPublished

This text of 612 So. 2d 839 (In re the Succession of Vicaro) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Succession of Vicaro, 612 So. 2d 839, 1992 La. App. LEXIS 4217, 1992 WL 410164 (La. Ct. App. 1992).

Opinion

GONZALES, Judge.

On June 28, 1983, Mrs. Hazel Sumlin Vicaro and her husband, Mr. Carl Vicaro, executed statutory wills. These wills were drawn up by the -Vicaro family attorney of many years. The Vicaros had no children. In Mrs. Vicaro’s will, she divided her property equally between her family (the Sum-lin heirs) and her husband’s family (the Vicaro heirs), in the event that her husband predeceased her. This was in accordance with her husband’s wishes for the disposal of their property. Mr. Vicaro passed away two months after the wills were executed.

On October 20, 1985, Mrs. Vicaro wrote an olographic will, which expressly revoked all previous wills and left all of her possessions, assets and property to her sister, Mrs. Louise Briggs. This olographic will was written, signed and dated by Mrs. Vi-caro in the presence of two witnesses, who were both notaries. The Vicaro family attorney was unaware that Mrs. Vicaro had written a second will on her own. Some months later, Mrs. Vicaro contacted the Vicaro family attorney and told him she wanted to leave $25,000 to a close family friend. The attorney wrote a codicil, which Mrs. Vicaro signed. This codicil made reference to the 1983 will which the attorney had written.

On December 2, 1990, Mrs. Vicaro died in East Baton Rouge Parish. On February 1, 1991, a petition was presented to the 19th Judicial District Court by the Vicaro heirs requesting probate of the 1983 will and the codicil of May 15, 1986. On February 4, 1991, a petition to probate the olographic will of 1985 and the 1986 codicil was presented to the Court by Mrs. Briggs. This petition also requested that the court nullify the 1983 statutory will.

The matter was submitted to the court by joint stipulation on the record and affidavits.1 The court made a final judgment holding the 1985 olographic will invalid and upholding the validity of the 1983 testamentary will and the 1986 codicil. A sus-pensive appeal was filed by Mrs. Briggs.

The first sentence of the 1985 olographic will states “I, Hazel S. Vicaro, being of sound mind and body, hereby make this my last will and testament, revoking all other wills previously made by me.” The last sentence of the olographic will states “Anything I may have written or declared in the past contrary to this will is null and void.” The 1986 codicil states:

[841]*841I, Mrs. Hazel Sumlin Vicaro, born Sum-lin, amend my Will of June 28, 1988 by the addition of the following:
I will and bequeath to my and my husband’s very good friend and advisor, Ed Campbell, the sum of TWENTY-FIVE THOUSAND AND NO/lOO ($25,-000.00) DOLLARS in cash to be paid at the time of my death, free of any inheritance taxes.
In all other respects my Will of June 28, 1983 is to remain the same.
Signed at Baton Rouge, Louisiana on this 15TH day of May, 1986.

The narrow legal issue before us is whether the wording of the 1986 codicil is sufficient to revoke the 1985 will and thus reinstate the 1983 will. Louisiana Civil Code article 1691 provides in part:

Testaments are revocable at the will of the testator until his decease. Prior to its amendment in 1987, Louisiana Civil Code article 1691 provided in pertinent part as follows:

The revocation of testaments by the act of the testator is express or tacit, general or particular.
It is express when the testator has formally declared in writing that he revokes his testament, or that he revokes such a legacy or a particular disposition.
It is tacit when it results from some other disposition of the testator, or from some act which supposes a change of will.
It is general when all the dispositions of a testament are revoked.
It is particular when it falls on some of the dispositions only, without touching the rest....

In Jones v. Mason, 234 La. 116, 99 So.2d 46, 48 (1958), multiple copies of one will surfaced after the decedent’s death. The court stated:

As we have said, the will in question— for there is only one will although duplicate originals of it exist — was entirely written, dated, and signed by the testator, and is valid in form as an olographic will. Since it has been proven to have been validly executed, the burden of proving revocation rests upon the opponents who assert revocation. See Throckmorton v. Holt, 180 U.S. 552, 21 S.Ct. 474, 45 L.Ed. 663 [(1901)]; Annotation, 165 A.L.R. 1188; 57 Am.Jur. 374, Wills, Sec. 541. (Emphasis added)

Louisiana Civil Code article 1588 provides:

The olographic testament is that which is written by the testator himself.
In order to be valid, it must be entirely written, dated and signed by the hand of the testator. It is subject to no other form, and may be made anywhere, even out of the State.

The olographic will was introduced into evidence and an affidavit was filed into the record, signed by notaries Cyd Sheree Page and William F. Page Jr., stating that Mrs. Vicaro wrote, dated and signed the will in their presence. The olographic will having been thus proven to be validly executed, the burden of proving revocation rests upon the Vicaro heirs. The Vicaro heirs cite Succession of Moran, 479 So.2d 350 (La.1985) as authority for their position that the codicil revokes the 1985 will. The first Moran will, written in 1976, left some of the decedent’s real estate to her two nephews. A later codicil written by decedent left that same piece of property to someone else. The court found that the codicil constituted a tacit revocation of the earlier bequest in the will. The rest of the will was still valid. The Moran case simply holds that a subsequent disposition of property amends a prior disposition to the extent that the two are inconsistent. Mrs. Vicaro’s 1985 will and 1986 codicil are only inconsistent to the extent that the codicil donates $25,000 to Ed Campbell.

Mrs. Briggs argues that the language of the 1986 codicil, although referencing the 1983 will, is not sufficient to revoke the 1985 will. A case cited by Mrs. Briggs as support for her position is Succession of Barry, 188 So.2d 124 (La.App. 4th Cir.1966), reversed on other grounds, 250 La. 435, 196 So.2d 265 (1967). The Barry case is factually similar to the case sub judice. In Barry, the decedent executed a will on July 7, 1960, leaving everything to one group of people, then executed a second will on January 2, 1962, leaving [842]*842everything to a different set of people. The decedent then executed a codicil, dated January 15, 1962, which stated that it was a codicil to the first (1960) will. The first issue which faced the Court of Appeal was whether the second document had the necessary dispositive language to be a will. The court held that it did. The second issue was whether the second will revoked the first will. The court held that the second will revoked the first because they were totally inconsistent. The final issue was the one that faces this Court: what effect should be given the codicil which referred to the first will? The court stated “[I]t is our opinion that said instrument has reference to the latter will, as opposed to the former.” 188 So.2d at 127.

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Related

Throckmorton v. Holt
180 U.S. 552 (Supreme Court, 1901)
Succession of Moran
479 So. 2d 350 (Supreme Court of Louisiana, 1985)
Jones v. Mason
99 So. 2d 46 (Supreme Court of Louisiana, 1958)
Succession of Barry
196 So. 2d 265 (Supreme Court of Louisiana, 1967)
Succession of Barry
188 So. 2d 124 (Louisiana Court of Appeal, 1966)

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Bluebook (online)
612 So. 2d 839, 1992 La. App. LEXIS 4217, 1992 WL 410164, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-succession-of-vicaro-lactapp-1992.