This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case concerns the estate of an elderly man, Fred Strozzi, who inherited a $1 million ranch from his brother in 1987. Shortly after, two respondents, who were distantly related to Strozzi, began visiting him frequently and later moved onto his property to care for him. In 1988, Strozzi revoked a prior will that left his estate to a neighbor and executed a new will leaving most of his estate to the respondents. After Strozzi's death in 1992, his blood relatives challenged the will, alleging undue influence by the respondents (paras 2-6).
Procedural History
- District Court of Socorro County: A jury found that the will was procured through undue influence and set it aside, though it determined that Strozzi had testamentary capacity (para 6).
Parties' Submissions
- Petitioners-Appellees: Argued that the will was void due to undue influence exerted by the respondents and that Strozzi lacked testamentary capacity (para 6).
- Respondents-Appellants: Contended that the jury instructions on undue influence were erroneous, particularly regarding the necessity of a confidential relationship, and that the petitioners failed to establish a prima facie case of undue influence (paras 7-9, 13).
Legal Issues
- Was the jury properly instructed on the elements of undue influence, including the necessity of a confidential relationship?
- Did the petitioners establish a prima facie case of undue influence?
- Was the trial court's definition of "natural objects of one's bounty" erroneous and prejudicial?
- Did the lack of statutory notice to a beneficiary of a prior will affect the validity of the proceedings?
Disposition
- The Court of Appeals affirmed the jury's verdict setting aside the will due to undue influence (para 23).
Reasons
Per Bosson J. (Alarid and Hartz JJ. concurring):
Jury Instructions on Undue Influence: The court assumed, without deciding, that a confidential relationship is a necessary element of undue influence. However, it found that any omission in the jury instructions was harmless because the evidence overwhelmingly demonstrated a relationship of trust and confidence between Strozzi and the respondents. The jury could not have found undue influence without also finding such a relationship (paras 10-12).
Prima Facie Case of Undue Influence: The court held that the petitioners presented substantial evidence of undue influence, including the respondents' close involvement in Strozzi's life, their financial control over him, and suspicious circumstances surrounding the will's execution. This evidence supported the jury's verdict (paras 13-16).
Definition of "Natural Objects of One's Bounty": The court rejected the respondents' argument that the trial court's definition was erroneous or prejudicial. It noted that the jury found Strozzi had testamentary capacity, rendering the issue moot. Additionally, there was no evidence that the jury misapplied the definition to the undue influence claim (paras 17-20).
Notice to Beneficiary of Prior Will: The court found that statutory notice was not required for the beneficiary of a revoked will that was not offered for probate. Moreover, the beneficiary had abandoned any claims to the estate, making the issue moot (paras 21-22).