Hoover v. Sims

DUNN, Justice,

dissenting.

I respectfully dissent.

Appellant’s bill of review challenged the authenticity of a handwritten document that a probate court accepted as a holographic will. Holographic wills must be supported by written documentation of authenticity. Tex.Prob.Code Ann. art. 84(b) (Vernon 1980). A contestant may obtain the annulment of a will which has already been admitted to probate by demonstrating that one or more of the statutory requirements for making and probating a valid will have not been fulfilled. Lee v. Lee, 424 S.W.2d 609, 610 n. 1 (Tex.1968). “Thus if the contest is initiated at this stage [post admission], the contestant’s burden is limited to offering evidence which negates the proponent’s attempt to carry the burden of persuasion.” W. Dorsaneo & L. Larson, 16 Texas Litigation Guide § 392.08[7][a] (1989). Here, the proponent did not initially fulfill statutory requirements; thus the *175statutory bill of review contestant simply had to call this fact to the court’s attention. Appellant’s bill of review challenged the authenticity of the handwriting, causing the court to review the record to determine statutory compliance. Finding error on the face of the record, I would remand and require the proponent of the will bear the burden of supplying the missing proof required to support a holographic will.

Appellant’s points of error one through three allege that the district court had insufficient evidence to affirm the probate court’s admission of the will. The record before us, which was also before the district court, contains no evidence that the handwriting is authentic. Section 84(b) of the Probate Code requires:

If not self-proved as provided in this Code, a will wholly in the handwriting of the testator may be proved by two witnesses to his handwriting, which evidence may be by sworn testimony or affidavit taken in open court, or, if such witnesses are nonresidents of the county or are residents who are unable to attend court, by deposition, either written or oral, taken in the same manner and under the same rules as depositions taken in other civil actions.

Tex.PROB.Code Ann. art. 84(b) (Vernon 1980) (emphasis added). Appellant’s statutory bill of review questions the authenticity of the handwriting, which requires the district court (and this Court) to review statutory compliance. Appellant’s authenticity challenge must be resolved from the face of the record, which indicates that the document was accepted as a holographic will without the required supporting evidence.

I differ from the majority on the issue of burden of proof. The majority takes the approach that appellant (contestant) needs to produce evidence which attacked an existing will. Appellant did not challenge a will, he asserted there never was a will. As such, he had a minimal burden of proof. He simply needed to show that the record did not contain the necessary proof to support a holographic will. Further, the district court stated at the hearing on the statutory bill of review that there was no proof supporting the holographic will. Thus the error is clear from the face of the record, and appellant challenges the authenticity by noting that the statute was not complied with. The majority accepts the probate court’s unsubstantiated finding that the handwritten document is an authenticated holographic will and concludes that it is appellant’s burden to disprove that the will is not properly authenticated. If it appeared from the record that the handwritten document was a valid holographic will supported by the proof required in section 84(b), the majority’s approach would be valid. In this case, however, the holographic will was never authenticated by appellee as required.

If the proponent proved the document in accordance with section 84, and made a record, the document would enjoy prima facie authenticity. Appellant’s challenge would then proceed on more difficult evi-dentiary terrain. It is in this context in which this Court decided Hamilton v. Jones, 521 S.W.2d 350 (Tex.Civ.App.—Houston [1st Dist.] 1975, writ ref’d n.r.e.), which the majority cites. Only when the proponent of a will makes a prima facie case is a challenger required to “specifically allege and prove substantial errors by the trial court.” 521 S.W.2d at 353. Here, the challenger questioned a document which was never proven to be a will. Thus, the challenger can “specifically allege and prove substantia] error” by referring to the lack of proof which is readily apparent from the face of this record.

I would remand for further evidentiary proceedings in accordance with the foregoing and refer the majority to the approach adopted in Jackson v. Thompson, 610 S.W.2d 519, 523 (Tex.Civ.App.—Houston [1st Dist.] 1980, writ ref’d n.r.e.), in which this Court reviewed the sufficiency of the record in a probate matter to determine that a county court erred as matter of law by admitting a codicil to probate as a muniment of title. As Judge Coleman found:

The record does not reflect evidence that there were no unpaid debts owing by the estate of the testator nor does it contain *176evidence constituting a sufficient reason for the court to find no necessity for administration upon the estate. In the absence of a sufficient evidentiary basis for these findings the court erred as a matter of law by admitting the will to probate as a muniment of title.

Id. (emphasis added). This Court has the power to independently review the eviden-tiary sufficiency of the record and correct errors below.

Therefore, I would reverse the judgment and remand the cause to the trial court.