Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

Thursday, June 29, 2006

Validity of Holographic Wills

In Berry v. Trible, 626 S.E.2d 440 (Va. 2006), the court reiterated the criteria for holographic wills. The handwriting must stand alone if the document is to be a valid holographic will. The court reversed the admission to probate of handwritten additions to a typewritten document because the handwritten language was “interwoven with the text, both physically and in sequence of thought” and the typewritten language therefore could not be ignored as surplusage.


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