Langston v. Williams
57 So. 3d 618
| Miss. | 2011Background
- Patricia Langston and Mansfield Langston were a married couple who held the marital home and a $200,000 certificate of deposit in joint tenancy with right of survivorship; Patricia died with a will that left nothing to Mansfield.
- After Patricia’s death, the chancery court found a confidential relationship existed and imposed the burden on Mansfield to prove absence of undue influence.
- The chancery court set aside Mansfield’s survivorship rights in both the home and the certificate of deposit because Mansfield failed to meet that burden.
- The Court of Appeals reversed the chancery court for presuming undue influence, but remanded or modified the judgment in parts; the supreme court granted review to address the correct burden of proof and whether Genna extends to inter vivos gifts.
- The supreme court holds that the confidential-spouse relationship does not raise a presumption of undue influence for inter vivos gifts and that the contestant bears the burden of proving undue influence, remanding for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Genna v. Harrington extend to inter vivos gifts between spouses? | Estate argues Genna applies to inter vivos gifts. | Mansfield contends Genna does not extend; burden shifts to him. | Yes; Genna applies to inter vivos gifts. |
| Does a confidential husband–wife relationship create a presumption of undue influence for inter vivos transfers? | Estate contends presumption exists after confidential relationship. | Mansfield contends no automatic presumption. | No automatic presumption; burden on contestant. |
| Who bears the burden of proving undue influence after the correct standard is applied? | Estate should prove Mansfield used undue influence. | Mansfield argues the estate bears burden; burden must be on contestant. | Burden on contestant to prove undue influence; remand for trial. |
Key Cases Cited
- Genna v. Harrington, 254 So.2d 525 (Miss.1971) (confidential spouse relationship does not create presumption of undue influence in testamentary gifts; burden on contestant to show undue influence for will)
- Madden v. Rhodes, 626 So.2d 608 (Miss.1993) (confidential relationship may create different standards for gifts; inter vivos gifts may carry automatic or no presumption depending on context)
- Spencer v. Hudspeth, 950 So.2d 238 (Miss.Ct.App.2007) (confidential relationship in inter vivos gift; earlier view treated burden differently)
- Langston v. Williams, 57 So.3d 657 (Miss.Ct.App.2010) (Court of Appeals citation discussed in analysis)
- Estate of Dunn v. Reilly, 784 So.2d 935 (Miss.2001) (citied for standard of review and evidentiary sufficiency)