62 Cal.App.5th 112
Cal. Ct. App.2021Background
- Decedent Catherine “Kay” Pearson executed a trust on February 24, 2016 naming St. Jude Children’s Research Hospital the sole beneficiary and expressly disinheriting her son and two granddaughters (appellants Eyford and Johnson).
- Appellants petitioned under Probate Code §6100.5(a)(2), alleging Kay had a mental health disorder with delusions or hallucinations that caused her to disinherit them.
- After Bob’s death in Oct. 2015 Kay was hospitalized for a UTI and exhibited confusion/delirium and later began accusing appellants of stealing, trying to get her declared incompetent, and attempting to harm her.
- Appellants took steps in late Oct. 2015 (powers of attorney, bank access, attorney visits) that Kay later described as coercive; Kay met with multiple attorneys and ultimately signed a St. Jude trust in Feb. 2016.
- Experts and witnesses conflicted: some testified Kay had transient delirium in late 2015 but was lucid on the day she signed the trust; other witnesses described memory problems and persistent suspicious statements. Trial court found insufficient proof of a qualifying delusional disorder at the time of the trust execution.
- The Court of Appeal affirmed, holding there was substantial evidence Kay did not suffer a mental health disorder with delusions operational when she signed the trust, so §6100.5(a)(2) did not invalidate the trust.
Issues
| Issue | Plaintiff's Argument (Eyford) | Defendant's Argument (Nord/St. Jude) | Held |
|---|---|---|---|
| Whether trust invalid under Prob. Code §6100.5(a)(2) because Kay had delusions that caused her to disinherit appellants | Kay harbored multiple delusions about appellants (theft, attempted murder, coercion) that motivated the trust and therefore lacked testamentary capacity | Kay’s false beliefs were tethered to facts or reasonable inferences; experts found only transient delirium in Oct. 2015 and no delusional disorder when trust was signed | Affirmed: substantial evidence supports trial court that Kay did not have a mental health disorder with delusions when she executed the trust |
| Whether appellate standard is de novo or substantial evidence | Appellants suggested de novo because trial court addressed a limited factual dispute | Respondents argued outcome depended on credibility and disputed facts, requiring substantial evidence review | Substantial evidence standard applies because resolution turned on disputed factual determinations |
| Whether §6100.5(a)(2) requires a mental health disorder in addition to delusions | Appellants argued statute’s focus is on delusions at signing, not a required clinical diagnosis | Respondents contended statute requires delusions arising from a mental health disorder; absent that disorder §6100.5(a)(2) is not met | Court: §6100.5(a)(2) requires a mental health disorder producing delusions; appellants’ late argument that disorder need not be found was untimely and legally unpersuasive |
| Whether trial court erred by not addressing every alleged false belief as a delusion | Appellants argued the court should have analyzed each belief separately and found many were delusions | Respondents argued the court need only make ultimate findings and substantial evidence showed no qualifying disorder at signing | Court rejected claim as unnecessary: substantial evidence that no mental health disorder existed at signing made further parsing of each belief unnecessary |
Key Cases Cited
- Estate of Putnam, 1 Cal.2d 162 (Cal. 1934) (defines delusion and holds beliefs grounded in any factual evidence or reasonable inference are not delusions)
- Estate of Alegria, 87 Cal.App.2d 645 (Cal. 1948) (evidence, however slight, that supports a belief defeats characterization as delusion)
- In re Estate of Perkins, 195 Cal. 699 (Cal. 1925) (testamentary capacity does not require logical reasoning or freedom from prejudice)
- Estate of Sarabia, 221 Cal.App.3d 599 (Cal. 1990) (testamentary competence is presumed)
- Andersen v. Hunt, 196 Cal.App.4th 722 (Cal. 2011) (§6100.5 principles applied to trusts that function like wills)
- Goodman v. Zimmerman, 25 Cal.App.4th 1667 (Cal. 1994) (discusses delusions in will contests and related evidentiary issues)