Louis Dickson v. John E. Swain

CourtCourt of Appeals of Texas
DecidedSeptember 26, 2006
Docket14-05-00062-CV
StatusPublished

This text of Louis Dickson v. John E. Swain (Louis Dickson v. John E. Swain) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Louis Dickson v. John E. Swain, (Tex. Ct. App. 2006).

Opinion

Affirmed and Memorandum Opinion filed September 26, 2006

Affirmed and Memorandum Opinion filed September 26, 2006.

In The

Fourteenth Court of Appeals

____________

NO. 14-05-00062-CV

LOUIS DICKSON, Appellant

V.

JOHN E. SWAIN, Appellee

On Appeal from the County Court at Law No. 3

Fort Bend County, Texas

Trial Court Cause No. 17,298

M E M O R A N D U M   O P I N I O N

This is an appeal from a will contest filed by a step-son against the independent executor of his step-mother=s estate.  The contestant alleged the testatrix lacked testamentary capacity to execute her will.  Returning a verdict against the contestant, a jury found that the testatrix had testamentary capacity on the day she signed the will.  The contestant now challenges the trial court=s denial of his motion for  judgment notwithstanding the verdict. We conclude the evidence is legally sufficient to support the jury=s finding, and we affirm the trial court=s judgment.


I.  Factual and Procedural Background

Agnes Dickson died on August 24, 2002, at the age of ninety-one years.  At the time of her death, she lived in Fort Bend County, Texas.  Two  and a half years before she died, on February 15, 2000, Agnes signed her last will and testament at the office of her attorney, John E. Swain, who was also the independent executor named in the will.  Tyler Swain and Barbara Kocian witnessed the signing of the will.  Less than a week after Agnes=s death, John Swain filed an application for probate of Agnes=s will. 

Louis Dickson, Agnes=s step-son filed a will contest alleging improper execution of the will, lack of testamentary capacity, and undue influence.  A jury returned a verdict in favor of admitting the will to probate.  The jury found that Agnes had testamentary capacity at the time she executed the will. The trial court admitted the will to probate upon entry of judgment on  the jury verdict.  Louis filed a motion for judgment notwithstanding the verdict requesting that the trial court disregard the jury=s verdict and arguing that the evidence proved that Agnes did not have testamentary capacity at the time she executed the will.  Louis did not raise any other issues in this motion, nor did he file a motion for new trial challenging the factual sufficiency of the evidence.

II.  Issue Presented

Louis presents the following issue on appeal:


The issue presented by appellant is whether the trial court erred in not granting the Plaintiff=s Motion for Judgment Notwithstanding the Verdict because the evidence presented at trial was legally insufficient to support the jury=s verdict that the testatrix had the required testamentary capacity[1] at the time of the will=s execution, and whether the jury=s finding that the will had been properly executed is against the overwhelming weight of the evidence. [2]

III.  Standard of Review

At any course of trial proceedings, judgment without or against a jury verdict is proper only when the law does not allow reasonable jurors to decide otherwise. City of Keller v. Wilson, 168 S.W.3d 802, 823 (Tex. 2005).  The test for legal sufficiency is the same for directed verdicts and judgments notwithstanding the verdict.  Id.  When reviewing the legal sufficiency of the evidence, we review the evidence in the light most favorable to the challenged finding and indulge every reasonable inference that would support it.  Id. at 822. We credit favorable evidence if a reasonable factfinder could, and disregard contrary evidence unless a reasonable factfinder could not. Id. at 827.  The evidence is legally sufficient if it would enable fair‑minded people to reach the verdict under review.  Id.

IV.  Analysis


Louis complains that the evidence adduced at trial is legally insufficient to support the jury=s finding that Agnes had testamentary capacity at the time she signed her will.  The Texas Probate Code requires proof that the will=s testatrix had a Asound mind@ before probate will be allowed.  See Tex. Prob.Code Ann. ' 88(b)(1) (Vernon 1980).  Texas courts have defined Asound mind@ to mean Atestamentary capacity.@  See Chambers v. Chambers, 542 S.W.2d 901, 906 (Tex. Civ. App.CDallas 1976, no writ).  Thus, to form a valid will the testatrix must have had Atestamentary capacity@ when the will was executed.  See id. at 906.

A testatrix has testamentary capacity when she has sufficient mental ability to understand that she is making a will, the effect of making a will, and the general nature and extent of her property.  Bracewell v. Bracewell, 20 S.W.3d 14, 19 (Tex. App Houston [14th Dist.] 2000, no pet.).  She also must know the natural object of her bounty, the claims upon them, and have sufficient memory to collect in her mind the elements of the business transacted and hold them long enough to form a reasonable judgment about them.  Id.  In a will contest, the pivotal issue is whether the testatrix had testamentary capacity on the day the will was executed. Lee v. Lee, 424 S.W.2d 609, 611 (Tex. 1968).  However, evidence of the testatrix=

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Republic Underwriters Insurance Co. v. Mex-Tex, Inc.
150 S.W.3d 423 (Texas Supreme Court, 2004)
Bracewell v. Bracewell
20 S.W.3d 14 (Court of Appeals of Texas, 2000)
Dow Chemical Co. v. Francis
46 S.W.3d 237 (Texas Supreme Court, 2001)
Miles v. Royal Indemnity Co.
589 S.W.2d 725 (Court of Appeals of Texas, 1979)
Bayou Terrace Investment Corp. v. Lyles
881 S.W.2d 810 (Court of Appeals of Texas, 1994)
Long v. Long
196 S.W.3d 460 (Court of Appeals of Texas, 2006)
Croucher v. Croucher
660 S.W.2d 55 (Texas Supreme Court, 1983)
Chambers v. Chambers
542 S.W.2d 901 (Court of Appeals of Texas, 1976)
Cruz v. Prado
239 S.W.2d 650 (Court of Appeals of Texas, 1951)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Webb v. Jorns
488 S.W.2d 407 (Texas Supreme Court, 1972)
Bell v. Bell
248 S.W.2d 978 (Court of Appeals of Texas, 1952)
Leyva v. Pacheco
358 S.W.2d 547 (Texas Supreme Court, 1962)
Lee v. Lee
424 S.W.2d 609 (Texas Supreme Court, 1968)

Cite This Page — Counsel Stack

Bluebook (online)
Louis Dickson v. John E. Swain, Counsel Stack Legal Research, https://law.counselstack.com/opinion/louis-dickson-v-john-e-swain-texapp-2006.