In the Matter of the Estate of John W. Simpson.

CourtMassachusetts Appeals Court
DecidedJanuary 3, 2025
Docket23-P-0689
StatusUnpublished

This text of In the Matter of the Estate of John W. Simpson. (In the Matter of the Estate of John W. Simpson.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Estate of John W. Simpson., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-689

IN THE MATTER OF THE ESTATE OF JOHN W. SIMPSON.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

John W. Simpson (Simpson) died leaving a will directing

that his sister was not to inherit from him. Instead, the will

provided that his girlfriend was to receive his entire estate.

Simpson's attorney offered an original will into probate that

had red marking over the name of Simpson's girlfriend as

beneficiary. Simpson's sister objected to the will's admission,

arguing that the marking indicated that Simpson had revoked the

will and therefore that he had died intestate with the result

being that she inherited the estate. After trial, a judge of

the Probate and Family Court determined that Simpson had not

revoked the will and admitted the will into probate. The sister

appeals. After review, we discern no error of law or abuse of

discretion, and therefore affirm. Background.1 Simpson met an attorney while playing golf in

2003. He told the attorney that he was interested in making an

estate plan. He explained that he had never married, had no

children, and wanted to ensure that his sister did not inherit

from him.2 Simpson executed a will on December 30, 2004, drafted

by the attorney, which nominated his girlfriend as executrix and

sole residuary beneficiary. The will stated, "I have made no

provision herein for my sister . . . for reasons known to me and

not by mistake or omission."

In July 2015, the attorney received a letter from Simpson,

requesting that the attorney destroy copies of the will. Rather

than destroy the copies, the attorney mailed them back to

Simpson. At some time in 2018 or 2019, Simpson contacted a

different lawyer and expressed an interest in writing a new will

with a different beneficiary.3 However, Simpson never executed a

new will. Likewise, in January 2019, Simpson contacted the

lawyer and again expressed an interest in creating a new will,

1 The facts are taken from the judge's written findings dated August 11, 2022.

2 The parties stipulated that the sister would have been Simpson's sole heir at law but for the will.

3 There is evidence in the record suggesting that Simpson's girlfriend became incapacitated at some point; a guardian ad litem was appointed to represent the girlfriend's interests.

2 although he had not yet decided to whom he intended to leave his

property. The lawyer never heard back from Simpson.

On February 4, 2020, Simpson got into a car accident and

was hospitalized. At the hospital, Simpson told his friend, to

whom he had given a power of attorney, that he did not want his

sister to visit him. Simpson told his girlfriend's son to go to

Simpson's home and retrieve the will to prevent his sister from

destroying it. At Simpson's home, the girlfriend's son found

Simpson's original will with red marking on it. Specifically,

and among other things, the clauses in the will naming Simpson's

girlfriend as the residuary beneficiary and executrix were

colored in with a red marker, with the original text visible

underneath. After Simpson's death, the sister entered Simpson's

home and found a copy of the will, on which the residuary clause

was marked up with a blue marker and the executrix clause was

crossed out.

The sister filed a petition for adjudication of intestacy

after the death of her brother. Thereafter, Simpson's attorney

filed a petition for probate of Simpson's 2004 will. After

trial, the judge allowed the attorney's petition, dismissed the

sister's petition, and admitted Simpson's will to probate.

Discussion. The sister argues that the judge's conclusion

that the will was not revoked does not follow from the facts

found and is not supported by the evidence or applicable law.

3 Specifically, she argues that the use of a red marker on the

original will constituted a revocatory act establishing that

Simpson intended to revoke the will.

Under Massachusetts law, a testator may revoke a will "by

performing a revocatory act on the will, if the testator

performed the act with the intent and for the purpose of

revoking the will." G. L. c. 190B, § 2-507 (a) (2).

"[R]evocatory act[s] on the will" include "burning, tearing,

canceling, obliterating, or destroying the will or any part of

it." Id.

The sister relies on Worcester Bank & Trust Co. v. Ellis,

292 Mass. 88 (1935), for the proposition that crossing out

clauses of a will constitutes cancellation even if the words are

still legible. That case involved the striking out of words

with a lead pencil. See id. at 90, 92. Here, by contrast, the

judge found that the marker used over the words, which could

still be seen through it, constituted highlighting, not striking

out. In any event, the legal import of a pencil strike versus a

marker is not the issue. As in Ellis, "[t]he real question

before us is one of fact," namely, whether Simpson intended to

revoke the will. Id. at 93 (even though pencil strike through

words constituted some evidence of cancellation, court reviewed

surrounding circumstances to determine whether facts supported

finding of intent to revoke will). See Batt v. Vittum, 307

4 Mass. 488, 490 (1940) (lines across certain paragraphs

"undoubtedly constitut[ed] sufficient marks of cancellation to

effect a revocation of these paragraphs if there was the

requisite intention to revoke them [emphasis added]"). See also

Bigelow v. Gillott, 123 Mass. 102, 106 (1877) ("the cancellation

by the testator of the sixth and thirteenth clauses of his will,

by drawing lines through them, with the intention of revoking

them, was a legal revocation of those clauses [emphasis

added]"). We give deference to the judge's factual findings

unless clearly erroneous. T.W. Nickerson, Inc. v. Fleet Nat'l

Bank, 456 Mass. 562, 569 (2010).4

The judge concluded that the sister did not meet her burden

of proving that the testator revoked the will. See Ellis, 292

Mass. at 92. The judge supported this conclusion by finding

that "[Simpson] did not intend for [the sister] to inherit any

part of his estate." Trial testimony from witnesses, credited

by the judge, supported this finding. Simpson's friend

4 The sister argues that our review of the documentary evidence, namely the original will, should be de novo. We disagree. Although "an appellate court may independently review documentary evidence . . .

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Related

First National Bank v. Briggs
108 N.E.2d 548 (Massachusetts Supreme Judicial Court, 1952)
In the Matter of the Estate of Beauregard
921 N.E.2d 954 (Massachusetts Supreme Judicial Court, 2010)
T.W. Nickerson, Inc. v. Fleet National Bank
924 N.E.2d 696 (Massachusetts Supreme Judicial Court, 2010)
Commonwealth v. Tremblay
107 N.E.3d 1121 (Massachusetts Supreme Judicial Court, 2018)
Bliss v. Thompson
4 Mass. 488 (Massachusetts Supreme Judicial Court, 1808)
Bigelow v. Gillott
123 Mass. 102 (Massachusetts Supreme Judicial Court, 1877)
Cummings v. National Shawmut Bank of Boston
188 N.E. 489 (Massachusetts Supreme Judicial Court, 1933)
Worcester Bank & Trust Co. v. Ellis
197 N.E. 637 (Massachusetts Supreme Judicial Court, 1935)
Commonwealth v. Ortiz
725 N.E.2d 1030 (Massachusetts Supreme Judicial Court, 2000)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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