Meadows v. Beam, 302 Ga. 494

Decedent (Dorothy Rita Beam), aged ~90, executed a 2014 will and a July 2014 codicil leaving the bulk of her estate to daughter Marian and largely disinheriting son John; Decedent had executed an earlier 2004 will dividing the estate equally among four children.
Marian petitioned to probate the 2014 will and codicil; siblings (Caveators: John, Margaret, Jayne) filed a caveat alleging Decedent lacked testamentary capacity; jury found for Caveators and awarded attorneys’ fees.
Medical and lay testimony showed Decedent suffered multiple chronic illnesses and exhibited confusion, memory lapses, and various false beliefs/delusions in 2013–2014 (e.g., mistaken employment offers, false beliefs that siblings were stealing from her).
Caveators presented a forensic psychiatrist who opined Decedent lacked capacity and was unduly influenced; Caveators conceded Decedent was not insane or monomaniacal but argued she had delusions and a fixed false belief about theft by siblings.
The trial court submitted the case to a jury; jury rejected claims of fraud, duress, and undue influence but found lack of testamentary capacity based on the evidence and awarded fees; Marian appealed.
Georgia Supreme Court reversed, holding evidence legally insufficient to rebut the presumption of capacity for a self-proved will and that Caveators failed to show Decedent suffered an insane delusion or unsound mind affecting the will.

Issue	Plaintiff's Argument (Marian)	Defendant's Argument (Caveators)	Held
Whether evidence sufficed to show Decedent lacked testamentary capacity when executing the 2014 will/codicil	The will was valid; evidence does not show lack of capacity	Decedent exhibited delusions, confusion, and false beliefs (including that siblings stole from her) demonstrating lack of capacity	Reversed: evidence legally insufficient; Decedent retained the modest cognitive ability required for testamentary capacity
Whether Caveators rebutted presumption of capacity for a self‑proved will and showed an insane delusion connected to the will	N/A (Marian relies on the presumption)	The presumption was rebutted by testimony of confusion/delusions and expert opinion that Decedent lacked capacity	Reversed: Caveators failed to rebut the presumption and conceded Decedent was not insane/monomaniacal; delusions shown were not insane delusions connected to the will

Patterson-Fowlkes v. Chancey, 291 Ga. 601 (discusses viewing evidence in the light most favorable to prevailing party and relevance of pre/post testamentary condition)
Odom v. Hughes, 293 Ga. 447 (explains elements of testamentary capacity: understanding will effect, remembering property and persons, and expressing disposition)
Boney v. Boney, 265 Ga. 839 (defines insane delusion standard and that not every delusion destroys testamentary capacity)
Reeves v. Webb, 297 Ga. 405 (presumption of capacity for self-proved wills and burden to rebut)
Brumbelow v. Hopkins, 197 Ga. 247 (distinguishes insane delusion from mistaken belief based on facts)
Holland v. Holland, 277 Ga. 792 (notes stringent standard required to set aside a will)