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Beckwith v. Dahl

California Court of Appeal

141 Cal. Rptr. 3d 142 (2012)

Relevant factsFree

Brent Beckwith (plaintiff) lived with his longtime partner, Marc MacGinnis, whose only living relative was his estranged sister, Susan Dahl (defendant). MacGinnis had drafted, but never signed, a will splitting his estate equally between Beckwith and Dahl; while hospitalized and in poor health, he asked Beckwith to prepare a new will, which Beckwith did and emailed to Dahl. Dahl told Beckwith not to give MacGinnis the will, promising instead to have an attorney draft trust documents within days. Before that happened, MacGinnis had life-threatening surgery; Dahl, as family, was informed of the danger, but Beckwith was not. MacGinnis's condition worsened, Dahl removed him from life support, and he died without a valid will. Dahl became administrator of the estate and, after months of ignoring Beckwith's requests for information, told him she would take the entire estate. The probate court found Beckwith lacked standing to contest the estate's distribution, so Beckwith filed a separate civil suit against Dahl for intentional interference with an expected inheritance (IIEI); the trial court dismissed it, holding California didn't recognize that tort. Beckwith appealed.

IssueFree

Whether a person who lacks standing in a probate proceeding may nevertheless state a claim for intentional interference with an expected inheritance against someone whose deliberate wrongful conduct toward the decedent caused the plaintiff to lose a reasonably expected inheritance.

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