Rudwick v. Lloyd

69 Va. Cir. 139, 2005 Va. Cir. LEXIS 319
CourtArlington County Circuit Court
DecidedOctober 13, 2005
DocketCase No. (Chancery) 05-86
StatusPublished
Cited by1 cases

This text of 69 Va. Cir. 139 (Rudwick v. Lloyd) is published on Counsel Stack Legal Research, covering Arlington County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rudwick v. Lloyd, 69 Va. Cir. 139, 2005 Va. Cir. LEXIS 319 (Va. Super. Ct. 2005).

Opinion

By Judge James F. Almand

In this case, the Court must determine whether the will signed by Regina E. Rudwick on April 3, 2001, was duly executed, whether she had sufficient testamentary capacity at the time the will was executed, and whether the will was the product of undue influence.

Having taken the matter under advisement and given the opportunity to review the exhibits, evidence, and arguments of the parties and the proposed findings of fact and conclusions of law submitted by the parties, I issue the following opinion resolving the outstanding issues.

[140]*140 Factual and Procedural Background

Regina Rudwick executed the contested will on April 3,2001. The will left $100,000 to Regina Rudwick’s son, Lawrence Rudwick, and the remainder of her sizable estate to her daughter, Nancy Lloyd. The will was prepared by Theresa Mihalik, a divorce lawyer who had represented Regina Rudwick in her recent divorce proceedings with her husband, Bernard Rudwick. Ms. Mihalik had advised Regina Rudwick and Nancy Lloyd that Ms. Rudwick should have a new will since her old one left everything to her husband, whom she was in the process of divorcing. Ms. Mihalik had drafted the will on April 2,2001, at the request of Ms. Lloyd, who told Ms. Mihalik that her mother wanted to draft a new will that left $50,000 to Lawrence Rudwick and the remainder of the estate to Ms. Lloyd. On April 3,2001, Ms. Lloyd drove her mother to Ms. Mihalik’s office, whereupon Ms. Mihalik showed them into a conference room and allowed Regina Rudwick to read the will on her own. When Ms. Mihalik returned, either Ms. Lloyd or Regina Rudwick told Ms. Mihalik that a change to the will was desired to increase the bequest to Lawrence from $50,000 to $100,000. Ms. Mihalik made the change to the document, gave it to Regina Rudwick to read once more, and then called three members of her staff into the conference room to witness and notarize Regina Rudwick’s execution of the will.

In his Bill of Complaint, Lawrence Rudwick challenges the will on the grounds that it was not properly executed, that Regina Rudwick lacked testamentary capacity at the time of the signing, and that the will was the product of undue influence by Nancy Lloyd.

During the eight-day trial stretching from August 1 to August 11,2005, the Court heard testimony from thirty witnesses regarding Regina Rudwick’s mental state, her relationship with her children, and the circumstances surrounding the execution of her last will. The Court has reviewed counsel’s proposed findings of fact and conclusions of law, evaluated the evidence and testimony presented at trial, and examined the relevant case law. For the reasons set forth below, the Court concludes that the will was properly executed, that Regina Rudwick had sufficient testamentaiy capacity at the time of execution, and that she was not subject to undue influence on the part of her daughter, Nancy Lloyd.

Due Execution of the Will

For a will to be valid, it must be signed by the testator in the presence of two competent witnesses, present at the same time, both of whom shall subscribe the will in the presence of the testator. See Ya. Code § 64.1-49. The burden of [141]*141proving that a will has been executed in the manner required is upon the proponent of the will. Triplett’s Ex’r v. Triplett, 161 Va. 906, 916, 172 S.E. 162, 166 (1934). A will can be self-proved by the acknowledgement of the testatrix and the affidavits of attesting witnesses that are attached or annexed to the will. Va. Code § 64.1-87.1.

In this case, the written will was signed by Regina Rudwick in the presence of three witnesses, all of whom were present at the same time and who subscribed in the presence of one another and the testatrix. As Theresa Mihalik testified, on April 3,2001, after allowing Regina Rudwick and Ms. Lloyd time to read through the will and make any changes or corrections, she asked four members of her staff to enter the conference room to witness and notarize the execution of the will. The testimony of two of the witnesses, the notary, and Nancy Lloyd supported the due execution of the will. Additionally, the will was self-proved through a clause contained in the will that substantially complied with the requirements set out in Va. Code § 64.1-87.1. As such, the Court is satisfied by a preponderance of the evidence that the will was properly executed in compliance with the statutoiy requirements.

Testamentary Capacity

“Testamentary capacity is the term used to describe the degree of mental capacity required for the valid execution of a will.” Gibbs v. Gibbs, 239 Va. 197, 199, 387 S.E.2d 499, 500 (1990), citing Va. Code § 64.1-47. The proponent of a will bears the evidentiaiy burden of proving the existence of testamentary capacity by a preponderance of evidence. Gibbs, 239 Va. at 199. Testamentary capacity existed at the time of execution if the testatrix was capable of recollecting her properly, the natural objects of her bounty and their claims upon her, understood the business about which she was engaged, and how she wished to dispose of her property. Thomason v. Carlton, 221 Va. 845, 852, 276 S.E.2d 171, 175 (1981). Testimony of witnesses as to the mental capacity of the testatrix at the time of execution carries great weight. Id. at 853.

The proponent of the will is entitled to a presumption that testamentary capacity existed by proving compliance with all statutoiy requirements for the valid execution ofthe will. Gibbs, 239 Va. at 200. Once this presumption is established, the contestant bears the burden of going forward with evidence to overcome this presumption, although the burden of persuasion remains with the proponent. Id., citing Redford v. Booker, 166 Va. 561, 569-70, 185 S.E. 879, 883 (1936).

The contestant in this case, Lawrence Rudwick, alleges that Regina Rudwick did not have sufficient testamentary capacity on April 3, 2001. In support of this allegation, Lawrence Rudwick brought forth a number of [142]*142witnesses who testified regarding Regina Rudwick’s mental condition in 2001, as well as experts who testified as to whether Regina Rudwick was suffering from Alzheimer’s disease or a mental deficiency during this period. To rebut the claim that Regina Rudwick lacked testamentary capacity, the will proponent, Nancy Lloyd, brought forth her own series of witnesses and experts, who testified that Regina Rudwick was not suffering from any debilitating mental deficiencies when she signed the will on April 3,2001.

The Court has considered the testimony and evidence presented by both parties and finds that while there is some evidence that raises concerns regarding Regina Rudwick’s mental condition prior to the date of execution, there is insufficient evidence to conclude that any mental deficiency had progressed to the point where •she lacked testamentary capacity on the date that she signed her will. The evidence shows that, at most, Regina Rudwick was suffering from the early stages of Alzheimer’s or mild dementia in the spring of 2001. However, even a finding of dementia or early Alzheimer’s would not be dispositive of the issues in this case. “Neither sickness nor impaired intellect is sufficient, standing alone, to render a will invalid.” Tabb v. Willis, 155 Va. 836, 859, 156 S.E. 556, 564 (1931).

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Bluebook (online)
69 Va. Cir. 139, 2005 Va. Cir. LEXIS 319, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rudwick-v-lloyd-vaccarlington-2005.