In the Matter of the Estate of Olson

CourtMassachusetts Appeals Court
DecidedMarch 21, 2024
DocketAC 23-P-210
StatusPublished

This text of In the Matter of the Estate of Olson (In the Matter of the Estate of Olson) 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 Olson, (Mass. Ct. App. 2024).

Opinion

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23-P-210 Appeals Court

IN THE MATTER OF THE ESTATE OF JEAN OLSON.

No. 23-P-210.

Plymouth. November 1, 2023. - March 21, 2024.

Present: Wolohojian, Neyman, & Shin, JJ.

Uniform Probate Code. Conservator. Will, Execution, Validity, Extrinsic evidence. Error, Harmless. Statute, Construction. Practice, Civil, Attorney's fees.

Petition filed in the Plymouth Division of the Probate and Family Court Department on July 9, 2019.

The case was heard by Edward F. Donnelly, Jr., J., on a motion for summary judgment.

Brian K. Lee for David D. Parker, Jr. Matthew H. Beaulieu for Anthony Lewandowski. John A. Gianino, for Paul L. Grzesik, was present but did not argue.

SHIN, J. The former conservator (conservator) of the

decedent, Jean Olson, filed a petition to probate a document

offered as Olson's will. The document, titled "Last Will and

Testament of Jean Olson," was prepared by the conservator in 2

consultation with Olson several months before her death,

attested to by two witnesses, and notarized. It was signed not

by Olson herself, however, but by the conservator in his name,

acting under the apparent, but mistaken, belief that he had the

power to execute a will on Olson's behalf.

Olson's nephew, Anthony Lewandowski, objected to the

conservator's petition and moved for summary judgment, arguing

that the document was not a valid will under G. L. c. 190B,

§ 2-502 (a), which requires that wills be signed by the testator

or by someone else in the testator's name.1 The conservator

responded that § 2-502 (a) contains an exception that allows the

use of extrinsic evidence to prove that a testator intended an

unsigned document to be her will. A Probate and Family Court

judge agreed with Lewandowski and dismissed the petition.

We conclude that in the specific circumstances of this case

-- where a separate statute (the conservatorship statute) allows

conservators with court authorization to execute wills on behalf

of other persons, and the conservator here acted on the belief

that he had such authorization -- the language creating the

exception to § 2-502 (a) is best construed to permit the use of

extrinsic evidence to establish that the unsigned document is a

1 Olson's nephew, Paul L. Grzesik, also filed an objection in the Probate and Family Court and joins in the brief filed by Lewandowski in this appeal. 3

valid will. A contrary reading would risk allowing a good faith

mistake of the conservator, a person specifically appointed by

the court to manage Olson's estate, to override Olson's

testamentary intent. As we do not believe this would be

consistent with the statutory purposes, we vacate the dismissal

of the petition and remand for further proceedings.2

Background. 1. Statutory framework. We begin with an

overview of the relevant statutes to provide context for the

issues raised by the appeal.

In 2009 the Legislature enacted G. L. c. 190B, § 2-502, as

part of the Massachusetts Uniform Probate Code (MUPC). See

St. 2008, c. 521, § 9. Section 2-502 states in full:

"[Execution of Wills.]

"(a) Except as provided in subsection (b) and in sections 2-506 and 2-513,[3] a will shall be:

"(1) in writing;

"(2) signed by the testator or in the testator's name by some other individual in the testator's conscious presence and by the testator's direction; and

2 We note that the conservator filed the notice of appeal before the decree was docketed. Because the objectors do not raise the issue and we see no prejudice, we reach the merits on appeal. See Liberty Mut. Fire Ins. Co. v. Casey, 91 Mass. App. Ct. 243, 244 n.2 (2017).

3 These sections concern, respectively, choice of law if a will is executed or a testator at the time of death is domiciled outside Massachusetts, and the admissibility of separate writings to dispose of items of tangible personal property. Neither is pertinent to this case. 4

"(3) signed by at least 2 individuals, each of whom witnessed either the signing of the will as described in paragraph (2) or the testator's acknowledgment of that signature or acknowledgment of the will.

"(b) Intent that the document constitute the testator's will can be established by extrinsic evidence." (Emphases added.)

As we will discuss, this case turns on the meaning of § 2-502's

opening clause, "[e]xcept as provided in subsection (b)."

Section 2-502 is modeled after the corresponding section of

the Uniform Probate Code (UPC)4 but differs in certain respects,

including that it omits the UPC provision authorizing

holographic wills (subsection [b] of UPC § 2-502). For

comparison we set out the full text of UPC § 2-502 in the

margin.5 Also, the MUPC does not contain a provision comparable

4 "The Uniform Probate Code is published by the Uniform Law Commission (also known as the National Conference of Commissioners on Uniform State Laws), a State-supported, national organization that proposes uniform codes for State legislatures to encourage uniformity and clarity in important areas of State law." American Family Life Assur. Co. of Columbus v. Parker, 488 Mass. 801, 804 n.5 (2022).

5 The full text of section 2-502 follows:

"(a) Except as otherwise provided in subsection (b) and in Sections 2-503, 2-506, and 2-513, a will must be:

"(2) signed by the testator or in the testator's name by some other individual in the testator's conscious presence and by the testator's direction; and 5

to UPC § 2-503, known as the harmless error provision. In

jurisdictions where it has been adopted, § 2-503 allows a court

to treat a document or writing as a valid will, even if "not

executed in compliance with Section 2-502," "if the proponent of

the document or writing establishes by clear and convincing

evidence that the decedent intended the document or writing to

constitute . . . the decedent's will." Uniform Probate Code

§ 2-503 (2006). See, e.g., Estate of Ehrlich, 427 N.J. Super.

64, 70-71 (2012). The purpose of § 2-503 is "to retain the

intent-serving benefits of Section 2-502 formality without

inflicting intent-defeating outcomes in cases of harmless

error." Uniform Probate Code § 2-503 comment (2006).

Article V, Part 4, of the MUPC governs conservatorships.

With respect to "a person who is disabled for reasons other than

"(3) signed by at least two individuals, each of whom signed within a reasonable time after he [or she] witnessed either the signing of the will as described in paragraph (2) or the testator's acknowledgment of that signature or acknowledgment of the will.

"(b) A will that does not comply with subsection (a) is valid as a holographic will, whether or not witnessed, if the signature and material portions of the document are in the testator's handwriting.

"(c) Intent that the document constitute the testator's will can be established by extrinsic evidence, including, for holographic wills, portions of the document that are not in the testator's handwriting."

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In the Matter of the Estate of Olson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-estate-of-olson-massappct-2024.