In the Matter of the Ronald R. Oldham Trust U/D/O 7/09/2007 Edward Oldham v. Stacey Oldham, 889 N.W.2d 671

Ronald Oldham created a revocable trust in July 2007 leaving a residential acreage and 90% of a farm to his son Edward and 10% to daughter Sheree; Edward lived on and farmed the property.
In 2011 Edward was charged with crimes including dependent adult abuse of Ronald and a no-contact order sent Ronald to assisted living; Ronald later returned home after the order was lifted.
On October 24 and November 2, 2011 Ronald signed amendments leaving the 90% farm interest in trust for Edward but ultimately payable to Edward’s daughter Stacey on his death, and deeding the acreage to Stacey at Ronald’s death.
Edward filed suit contesting the amendments, alleging Stacey unduly influenced Ronald to change the trust; trial occurred in December 2015 and the probate court upheld the amendments.
Evidence included testimony that Ronald was strong-willed, worried Edward might be forced to sell property because of criminal exposure, discussed keeping property in the family, and that Stacey had attempted (unsuccessfully) earlier to obtain a transfer of the acreage.
The probate court found Ronald not susceptible to undue influence, Stacey had opportunity but not disposition to unduly influence, and Edward failed to clearly prove causation; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review for trust contest	Edward: treat like will contest (law action) or equitable review; facts should be reviewed de novo	Court/Respondent: apply standard ensuring same remedies as will contests but findings supported by substantial evidence	Court: errors at law standard; findings of fact binding if supported by substantial evidence
Whether trust amendments were procured by undue influence	Edward: Stacey unduly influenced Ronald to amend trust to benefit Stacey and disfavor Edward	Stacey/Ronald estate: Ronald was capable, made changes for family-preservation reasons; Stacey lacked disposition and her contact occurred after amendments	Court: affirmed probate court — undue influence not proven (susceptibility, opportunity, disposition, causation not satisfied)

Mendenhall v. Judy, 671 N.W.2d 452 (Iowa 2003) (elements required to prove undue influence in trust/will contests)
Burkhalter v. Burkhalter, 841 N.W.2d 93 (Iowa 2013) (heightened proof required for causation element in undue-influence claims)
City of Cedar Rapids v. Mun. Fire & Police Ret. Sys., 526 N.W.2d 284 (Iowa 1995) (definition of substantial evidence)
In re Estate of Davenport, 346 N.W.2d 530 (Iowa 1984) (persuasion alone is insufficient; undue influence must dominate the testator's motives)