Succession of Jacob Bordelon

CourtLouisiana Court of Appeal
DecidedOctober 1, 2014
DocketCA-0014-0274
StatusUnknown

This text of Succession of Jacob Bordelon (Succession of Jacob Bordelon) 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 Jacob Bordelon, (La. Ct. App. 2014).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

14-274

SUCCESSION OF

JACOB BORDELON

**********

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 2012-902762-A HONORABLE WILLIAM BENNETT, DISTRICT JUDGE

JOHN D. SAUNDERS JUDGE

Court composed of John D. Saunders, Billy Howard Ezell, and J. David Painter, Judges.

AFFIRMED.

Robert Ronald Faucheux Jr. Law Offices of Robert R. Faucheux P. O. Box 1960 Laplace, LA 70069 (985) 651-2888 COUNSEL FOR APPELLANT: Lucas Desselle Henry Howard Lemoine, Jr. Attorney at Law 607 Main St. Pineville, LA 71360 (318) 473-4220 COUNSEL FOR APPELLANT: Lucas Desselle

W. Jay Luneau Luneau Law Office 1239 Jackson St. Alexandria, LA 71301 (318) 767-1161 COUNSEL FOR APPELLEE: Marilyn Bordelon SAUNDERS, Judge.

This is a succession case dealing with a will executed in 1999, a codicil

executed in 2010, and second codicil executed in 2011. At trial, Appellees

asserted the 2011 codicil was invalid because it was executed at a time the

decedent lacked testamentary capacity and was the product of undue influence.

The trial court found the decedent lacked testamentary capacity at the time the

2011 codicil was executed and that Appellant exerted undue influence on the

decedent. On appeal, Appellant raises three assignments of error. Appellees

answered the appeal, asserting the trial court erred in finding the 2011 codicil was

valid in form. For the reasons discussed herein, we affirm the trial court’s

judgment.

FACTS AND PROCEDURAL HISTORY

This case involves the testament of Jacob Bordelon (hereafter “decedent”)

and two codicils.

The decedent was the father of three children, Marsha, Vickie, and Wade,

and was married to Marilyn Bordelon. Marsha has a son, Lucas Desselle, who is

the Appellant. Vickie had two sons, Clint and Jase Arnouville. The decedent

made his living farming and raising cattle.

The decedent executed an original will on August 23, 1999, dividing naked

ownership of most of his estate amongst his children with a usufruct in favor of

Marilyn. Some items were bequeathed to his children free of the usufruct in favor

of Marilyn. On June 8, 2010, to reflect the acquisition of additional property, the

decedent executed a codicil to the original will. The 2010 codicil disposed of

additional property and amended some former legacies. Appellant was not a

legatee in either the 1999 will, or the 2010 codicil. On December 14, 2011, the

decedent executed a second codicil. The 2011 codicil granted naked ownership of the property formerly bequeathed to Wade to Appellant. Wade was left a usufruct

of the property formerly bequeathed to him in naked ownership. Several items

were bequeathed to Appellant in full ownership, unencumbered by the usufruct in

favor of Wade. Appellant had never been a legatee before.

The decedent died on August 8, 2012. Appellant filed a petition to probate

the decedent’s 1999 will and the 2011 codicil on October 16, 2012. On October 17,

2012, the original will and 2011 codicil were probated and Appellant was

appointed provisional administrator of the decedent’s estate. On November 9,

2012, the decedent’s wife, Marilyn, filed a Motion to Remove Provisional

Administrator, to File Original Will and Codicil, to Appoint Executrix, for

Authority to Lease Property, and to Continue Business Enterprises, in which she

alleged the 2011 codicil was unenforceable because the decedent lacked capacity

to execute it and because Appellant unduly influenced the decedent. A judgment

probating the original will and 2010 codicil was issued on May 10, 2013. On May

14, 2013, Appellant filed a Motion to Re-Fix Hearing on Rule to Show Cause,

alleging the May 10, 2013 judgment did not address the validity of the 2011 codicil.

After trial on the merits, judgment was rendered on January 21, 2014, declaring the

2011 codicil null. It is from this judgment that this appeal arises.

In June of 2011, Dr. James Quillan conducted a mental status examination

on the decedent, reporting that the decedent was not oriented as to time but was

able to speak fluently and coherently. His deposition testimony was admitted into

evidence at trial. Multiple witnesses testified that the decedent behaved unusually

and was confused in the months surrounding the execution of the 2011 codicil.

However, the attorney who notarized the 2011 codicil testified that the decedent

appeared coherent on the two days he met with him, including the day the 2011

codicil was executed. On the evening of December 14, 2011, following the 2 execution of the second codicil, the decedent inappropriately discharged a firearm

in his home.

Appellant spent a significant amount of time with the decedent throughout

his life and had a close relationship with the decedent. For many years, Appellant

helped the decedent with the farming and cattle operations. In the last few years of

the decedent’s life, the frequency of their contact decreased. However, Appellant’s

girlfriend, Kasey, spent a substantial amount of time with the decedent in the year

preceding his death, often taking him to doctors’ appointments, to visit friends, to

joyride, and to visit Appellant and others while they worked in the field. Marilyn

primarily cared for the decedent in the time preceding his death, although she was

often assisted by her children and Kasey.

In his appeal, Appellant raised the following assignments of error:

ASSIGNMENTS OF ERROR:

1. The trial court erred in finding that the decedent lacked testamentary

capacity.

2. The trial court erred in finding that Appellant exerted undue influence

on the decedent.

3. The trial court erred in denying Appellant’s motion in limine to

exclude the deposition testimony of Dr. James Quillin.

ASSIGNMENT OF ERROR NUMBER ONE:

Appellant asserts that the trial court erred by declaring the 2011 codicil null

on the grounds that the decedent lacked testamentary capacity. This assignment of

error is without merit.

“An appellate court may not set aside a trial court’s finding of fact absent

manifest error or unless it is clearly wrong.” Succession of Moss, 00–62, p. 3

(La.App. 3 Cir. 6/21/00), 769 So.2d 614, 617, writ denied, 00–2834 (La. 12/8/00), 3 776 So.2d 462 (citing Rosell v. ESCO, 549 So.2d 840 (La.1989)). “[T]he question

of testamentary capacity is a question of fact.” Succession of Ellis, 486 So.2d 260,

262 (La.App. 3 Cir.1986).

The trial court found the evidence showed the decedent “had the capacity to

execute the document and to understand the nature of the document, [but the

decedent] did not have the capacity to understand the consequences thereof,” and,

thus, that decedent “did not have the necessary testamentary capacity to execute

the Codicil in December 2011.” Therefore, the trial court found the 2011 codicil

invalid. To warrant reversal, Appellant must show that the trial court’s finding that

the decedent lacked testamentary capacity was manifestly erroneous or clearly

wrong.

To have the capacity to donate inter vivos or mortis causa, a person must be

able “to comprehend generally the nature and consequences” of his action.

La.Civ.Code art. 1477. “Capacity to donate mortis causa must exist at the time the

testator executes the testament.” La.Civ.Code art.

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