In the Matter of the Estate of Henry Matthew Platt v. the State of Texas

Texas Court of Appeals, 9th District (Beaumont)·Decided January 29, 2026·No. 09-24-00097-CV·Published

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

NO. 09-24-00097-CV

IN THE MATTER OF THE ESTATE OF HENRY MATTHEW PLATT, DECEASED

On Appeal from the 1st District Court Jasper County, Texas

Trial Cause No. 40130

MEMORANDUM OPINION

J’Nette Allred appeals the trial court’s order revoking her Letters of Administration in the Matter of the Estate of Henry Matthew Platt. 1 In three issues, J’Nette complains about the trial court’s evidentiary rulings. For the reasons discussed below, we affirm.

For ease, we will refer to the decedent and his family members by their first 1

names throughout the appeal.

Background

Henry Matthew Platt died on November 10, 2021. He was predeceased by his parents, Jack Platt and Dorothy Platt. At the time of his death, he was survived by three siblings: J’Nette Platt Allred, James Mark Platt, and Shirley Nell Waggoner Russell.2 Henry was also survived by a niece named Angela Clemmons. On January 31, 2022, J’Nette filed an Application for Letters of Administration alleging that Henry died intestate. The court signed an order on April 20, 2022, appointing J’Nette as independent administrator of Henry’s estate. Shirley and James subsequently filed pleadings contesting J’Nette’s appointment.

On March 15, 2023, Angela filed an Application to Probate a Holographic Will and for Issuance of Letters Testamentary. The application alleged that Henry left a valid will dated June 24, 2012, which was never revoked and named Angela to serve as independent executor. The application also asserted that the will was wholly in Henry’s handwriting and that his “signature is subscribed thereto.” The holographic will leaves Henry’s entire estate to Angela and appoints Angela to serve as independent executor without bond.

On February 14, 2024, the trial court held a bench trial on the will contest.

Several witnesses testified. Angela testified that Henry is her uncle and was like a

2 J’Nette Platt Allred’s name is Dorothy J’Nette Platt Bower West Allred according to her siblings’ response, but we refer to her as J’Nette.

“second father” to her. In 2012, Henry lived with Angela in Abilene because Henry was “having a hard time making ends meet” after the death of his parents, and Henry “had done so much for me during my life.” Angela claimed familiarity with Henry’s handwriting after seeing letters and cards he had written and watching him write his signature. Angela testified that she recognized the handwriting in the body of the will and that it appeared to be Henry’s handwriting. Angela further testified that she recognized the signature at the bottom of the will and that it was Henry’s signature as it was in 2012.

William Candler testified by deposition. William knew Henry for about twenty years. William explained that Henry knew he was ill and would pass away. William, who worked in real estate, knew “what happens when people die without wills[,]” and knew that Henry had an “intense dislike for [his] brother[,]” suggested that Henry should write a handwritten will. After researching how to draft a handwritten will, Henry asked William to use his desk and wrote the holographic will. William testified he witnessed Henry write the handwritten will.

William testified that the entire will was in Henry’s handwriting and contained Henry’s signature. William further testified that Henry signed the will in his presence. William was not surprised that Henry’s will left all his assets to Angela as William explained that Henry was “adamant he wanted her to have it because he had been living with her and she had spent money taking care of him.” After writing and

signing the will, Henry handed it to William in William’s office. William put the will in a file and then “kinda forgot about it.” William kept the will in his filing cabinet from June 24, 2012, until he relinquished possession of it. Nothing occurred which led William to believe that Henry replaced or revoked the handwritten will.

Vincent Jason Lour Blanc also testified by deposition. Vincent met Henry through rock clubs and the pair developed a friendship. During their friendship, Vincent saw Henry’s handwriting and his signature. Looking at the handwritten will dated June 24, 2012, Vincent testified that the will contains Henry’s handwriting and Henry’s signature.

Curt Baggett is a handwriting expert hired by J’Nette. When Baggett was called to testify, Angela’s counsel requested and obtained the trial court’s permission to question Baggett on voir dire to examine whether he was qualified to provide expert testimony. On voir dire, Baggett testified he never met Henry, nor did he meet Henry’s parents. Baggett indicated he was asked to examine several documents in this case. The first document, identified as “HMPQ1” was the holographic will dated June 24, 2012, which Baggett compared to other documents identified as “KI, K2, K3, K4, and K5[.]”Baggett agreed that HMPQ1 contains the name of Henry Matthew Platt but that documents K1, K2, K3, K4, and K5 do not. Instead, those documents contain the names of Jack Platt and Dorothy Platt. Baggett conceded he did not examine any other documents containing the handwriting of Jack Platt or

Dorothy Platt and never observed Henry, Jack, or Dorothy write or sign their individual names. Baggett testified that he examined documents K1 through K5 which had Jack Platt’s signature on them. According to Baggett, he understood at the time he examined the documents that Jack Platt’s signatures were actually written by Henry, but he admitted those documents did not contain Henry’s name or Henry’s purported signature.

Citing Texas Rules of Evidence 703 and 705, Shirley’s counsel then objected to Baggett’s testimony as an expert on the grounds his opinions were not “based on a good foundation of data” because he did not examine any documents with Henry’s name on them other than the handwritten will. Shirley’s counsel also objected that Baggett could not offer lay opinions because he had no personal knowledge of Jack’s, Dorothy’s, or Henry’s handwriting. Angela’s counsel joined in Shirley’s objection that Baggett’s testimony as an expert lacked sufficient foundation since Baggett had not shown that he compared Henry’s handwriting to the will in question, and the signatures Baggett analyzed were those of Jack and Dorothy, not Henry.

J’Nette’s counsel responded that the trial testimony had already established that Jack and Dorothy were blind and Henry took care of them, so the documents were provided for examination because Henry had signed them on Jack’s and Dorothy’s behalf. J’Nette’s attorney conceded that Baggett did not analyze any documents containing Henry’s signature but argued that J’Nette had witnessed

Henry signing one of the documents for his parents and offered to call J’Nette to testify as much. The trial court sustained the objection “for right now” but allowed J’Nette to testify before continuing with Baggett’s testimony.

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In the Matter of the Estate of Henry Matthew Platt v. the State of Texas, (Tex. Ct. App. 2026).

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