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 a dispute between siblings over their late mother's estate. The plaintiff alleged that the defendant, her brother, intentionally interfered with her expected inheritance by influencing their mother to transfer significant assets to him before her death, leaving no property to be divided equally as specified in the mother's will. The contested transfers included the mother's house, furniture, certificates of deposit, and a joint savings account.
Procedural History
- District Court of Lincoln County: The trial court ruled in favor of the plaintiff, finding that the defendant intentionally interfered with the plaintiff's inheritance by exerting undue influence over their mother. The court awarded damages to the plaintiff.
Parties' Submissions
- Plaintiff: Argued that the defendant intentionally and tortiously interfered with her expected inheritance by exerting undue influence over their mother, causing her to transfer assets to him before her death, contrary to her stated intent to divide the estate equally.
- Defendant: Contended that the transfers were legitimate and reflected their mother's intent to reward him for caring for her during her final years. He denied exerting undue influence and argued that the plaintiff's strained relationship with their mother justified the unequal distribution.
Legal Issues
- Was the tort of intentional interference with an expected inheritance actionable in New Mexico?
- Did the defendant intentionally and tortiously interfere with the plaintiff's expected inheritance by exerting undue influence over their mother?
- Was there sufficient evidence to support the trial court's findings regarding the transfers of the house, furniture, certificates of deposit, and joint savings account?
Disposition
- The Court of Appeals recognized the tort of intentional interference with an expected inheritance as actionable in New Mexico.
- The court affirmed the trial court's finding of undue influence regarding the transfer of the certificates of deposit and joint savings account, awarding damages to the plaintiff.
- The court reversed the trial court's finding of undue influence regarding the transfer of the house and its contents, holding that the evidence did not support this conclusion.
Reasons
Per Chavez J. (Black and Flores JJ. concurring):
The court recognized the tort of intentional interference with an expected inheritance, aligning with the Restatement (Second) of Torts § 774B and precedents from other jurisdictions. The court held that this tort requires proof of an expectancy, reasonable certainty of its realization but for the interference, intentional and tortious conduct, and damages.
Regarding the certificates of deposit and joint savings account, the court found substantial evidence of undue influence. The defendant had a confidential relationship with the mother, who was in a weakened physical and mental state due to illness. The defendant actively participated in procuring the transfers, concealed them from the plaintiff, and the transfers were inconsistent with the mother's prior intent to divide her estate equally.
In contrast, the court found insufficient evidence of undue influence concerning the transfer of the house and its contents. The mother appeared competent at the time, initiated the transfer herself, and disclosed it to the plaintiff. There was no evidence of domination or control by the defendant in this instance.
The court concluded that the trial court's findings were partially supported by substantial evidence and adjusted the judgment accordingly.