Succession of Bettye Lou Thomas Moore

CourtLouisiana Court of Appeal
DecidedMarch 30, 2022
Docket54,338-CA
StatusPublished

This text of Succession of Bettye Lou Thomas Moore (Succession of Bettye Lou Thomas Moore) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Succession of Bettye Lou Thomas Moore, (La. Ct. App. 2022).

Opinion

Judgment rendered March 30, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,338-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

SUCCESSION OF BETTYE LOU THOMAS MOORE

Appealed from the Sixth Judicial District Court for the Parish of Madison, Louisiana Trial Court No. 5,054

Honorable Laurie Reis Brister, Judge

THE RAYMOND LEE Counsel for Appellant, CANNON LAW FIRM, LLC Johnny Cardelle By: Raymond Lee Cannon McDonald

JEFFREY M. LANDRY Counsel for Appellee, Attorney General Madison Parish Registrar of Voters JEFFREY MICHAEL WALE Special Assistant Attorney General

HAYMER LAW FIRM Counsel for Appellees, By: Niles B. Haymer Lee A. Thomas; Joe Thomas, Jr.; Curtis Nash; Frankie T. Solomon; and Delores Kline

VIVIAN THOMAS KLINE In Proper Person, Appellee

STEVE THOMAS In Proper Person, Appellee

DAWN KLINE In Proper Person, Appellee

Before THOMPSON, ROBINSON, and O’CALLAGHAN (Pro Tempore), JJ. THOMPSON, J.

The siblings of a decedent challenged her purported olographic

testament alleged to have been written just hours before her death, asserting

it was neither written nor signed by the decedent. After a two-day trial that

included the testimony of several witnesses and an expert witness in forensic

document examination, the trial court found the testament to be invalid and

not to have been signed by the decedent. The former stepson of the

decedent, who was the primary beneficiary of the olographic testament,

appealed the trial court’s ruling, asserting 16 assignments of error. Finding

those assignments of error to be harmless or without merit, we affirm the

trial court’s judgment.

FACTS

The origin of the dispute in this matter is the validity of a purported

olographic testament (“will”) of Bettye Lou Thomas Moore (“Moore”), who

died of a heart attack at about 8:30 p.m. on December 9, 2018. The will was

allegedly written and signed by Moore at 3:46 p.m. on the day of her death.

The will is three pages in length including signatures, and names her former

stepson, Johnny “Cardelle” McDonald (“McDonald”), as the primary

beneficiary.

Moore’s siblings opposed the validity of the testament, which

contained numerous spelling, grammatical, and other errors, and asserted

that Moore was a notary public well-versed and experienced in preparing

last wills and testaments for people. They argued she had helped others

prepare wills on many occasions over the years and was familiar with the

legal requirements for those documents to be valid. They point to Moore’s education, experience in legal matters, her time as Registrar of Voters, and

her vast experience as a Notary Public preparing and notarizing wills as

evidence contrary to the assertion that Moore wrote or signed what they

asserted was a defective olographic testament, which inexplicably included

witness signatures and in which Moore notarized her own signature.

The applicable provisions of Louisiana’s Civil Code relative to

olographic testaments are in La. C.C. Art. 1575, which provides:

La. C.C. Art. 1575. Olographic testament

A. An olographic testament is one entirely written, dated, and signed in the handwriting of the testator. Although the date may appear anywhere in the testament, the testator must sign the testament at the end of the testament. If anything is written by the testator after his signature, the testament shall not be invalid and such writing may be considered by the court, in its discretion, as part of the testament. The olographic testament is subject to no other requirement as to form. The date is sufficiently indicated if the day, month, and year are reasonably ascertainable from information in the testament, as clarified by extrinsic evidence, if necessary.

B. Additions and deletions on the testament may be given effect only if made by the hand of the testator.

At trial on this matter, McDonald testified that Moore called him in

the morning on the day of her death, telling him she was not feeling well.

Before she went to the hospital later that day, the only people to see Moore

in her home were McDonald, his girlfriend, LeDedra Johnson (“Johnson”),

and Johnson’s friend, Antonya Dugano (“Dugano”). McDonald is the son of

Moore’s former husband. While there is conflicting testimony regarding just

how close Moore and McDonald were on the date of Moore’s death, it is

clear that they had a longstanding relationship and McDonald had known

Moore most of his life.

2 McDonald testified that after receiving Moore’s telephone call, he and

Johnson went to Moore’s house to see her. McDonald and Johnson testified

that they prepared food for Moore, went to the store for her, and watched

television with her. Johnson testified that at some point during the day,

Moore asked her to retrieve her books and a pen. They testified that Moore

was talking about her death, and McDonald, who was uncomfortable, left

the room. Johnson first testified that she saw Moore write, date, and sign the

will. She admitted on cross-examination, however, that she may not have

witnessed Moore draft the entirety of the will. McDonald also admitted on

cross-examination to not seeing Moore draft the entirety of the will or being

present for the witness signatures.

When Moore was allegedly almost done drafting the will, Johnson

called Dugano, her friend who did not know Moore, to come to the house to

witness the will, a step that is unnecessary for the validity of an olographic

will. Dugano testified that Johnson’s signature was already on the will when

she arrived at the house. Johnson and Dugano stated that they saw Moore

write a statement on the third page but did not know what she wrote. These

assertions are contrary to the contents of the will submitted for probate, as

there would be no statement for Johnson and Dugano to have seen Moore

write on the third page of the will. There is only a statement above Moore’s

signature, which would logically have already been on the will before Moore

signed the document. The will bears a date and time, and Moore is alleged

to have signed it of 3:46 p.m. on December 9, 2018.

Johnson left the home to get dinner, and when she returned, Moore

was ill. Johnson called 911 and was instructed to perform CPR. Moore was

3 taken to the Madison Parish Hospital and quickly thereafter died from a

heart attack.

The purported olographic will is three handwritten pages long,

allegedly signed and dated by Moore, and bequeaths the majority of her

estate to McDonald, including her two houses, her bank account, and two

vehicles (a GMC Hummer and a Nissan Juke). The remainder of her estate

was left to “her two youngest siblings Vivian Kline and Steve Thomas.”

Johnson and Dugano signed the will as witnesses, and for still unclear

reasons, Moore’s signature and notarial stamp are at the bottom of the final

page of the will under the signatures of the purported witnesses.

Testimony revealed that Moore had been the Registrar of Voters for

Madison Parish for a number of years and was known to carry a laptop

between work and her home. On the laptop, she prepared other people’s

wills for them. Multiple people testified at trial that Moore was a

professional woman who had worked at a law firm and had extensive

experience drafting wills and providing information to people to draft or

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