In the Matter of the Estate of Margaret E. Workman, Dennis Workman v. Gary Workman, Individually and as of the Estate of Margaret E. Workman, 903 N.W.2d 170

Margaret Workman executed multiple wills/codicils from 1983–2008; her final will (2007) and codicil (2008) gave a disproportionate share of farmland to son Gary, with precatory language explaining the reason.
Gary lived nearby and farmed with his parents for decades; Dennis lived elsewhere and had financial troubles. Margaret was intensely involved in estate planning and frequently revised documents.
After Margaret died in 2012, Dennis filed to set aside the 2007 will and 2008 codicil alleging undue influence and lack of testamentary capacity; the court dismissed the capacity claim but denied summary judgment on undue influence.
At trial Dennis presented evidence and, at the close of his case, sought to amend his pleadings to challenge all prior wills/codicils (1983–2008); the district court denied the late amendment as prejudicial and altering issues/defenses.
Jury instructions placed the burden on Dennis to prove undue influence (no burden-shifting); Dennis did not object to the instructions at the instruction conference. The jury found no undue influence as to the 2007 will and 2008 codicil.
The Iowa Supreme Court vacated the court of appeals decision and affirmed the district court: Dennis failed to preserve his argument about adopting the Restatement (Third) burden rule, and the trial court did not abuse discretion in denying the late amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether burden shifts to beneficiary when confidential relationship exists for testamentary transfers	Dennis: adopt Restatement (Third) §8.3 comment f — presumption of undue influence arises for any donative transfer when confidential relationship + suspicious circumstances exist	Gary: Iowa precedent distinguishes inter vivos vs testamentary transfers; no burden shift for wills; instructions placing burden on Dennis were correct	Not preserved for review — Dennis failed to object to jury instructions per Iowa R. Civ. P. 1.924; court declined to adopt Restatement rule here
Whether district court abused discretion by denying motion to amend pleadings at close of plaintiff's case to include all prior wills/codicils	Dennis: amendment necessary to conform pleadings to proof and allow jury to consider undue influence across earlier instruments	Gary: late amendment would substantially broaden issues, change proof and defenses, and unfairly prejudice him	No abuse of discretion — amendment would materially change issues and unfairly surprise/prejudice Gary; Dennis knew or should have known facts earlier

In re Estate of Todd, 585 N.W.2d 273 (Iowa 1998) (distinguishes burden-shifting for inter vivos transfers from testamentary transfers)
Meincke v. Nw. Bank & Tr. Co., 756 N.W.2d 223 (Iowa 2008) (denial of late amendment proper when movant knew supporting testimony before trial)
Kiesau v. Bantz, 686 N.W.2d 164 (Iowa 2004) (denial of summary judgment merges into trial when case proceeds to merits)
Woods v. Schmitt, 439 N.W.2d 855 (Iowa 1989) (rule 1.924 requires objections to instructions to preserve error)
Allison-Kesley Ag Ctr., Inc. v. Hildebrand, 485 N.W.2d 841 (Iowa 1992) (amendment to conform to proof may be denied when movant knew or should have known testimony beforehand)