Clark v. Greenhalge
Supreme Judicial Court of Massachusetts
582 N.E.2d 949 (1991)
Helen Nesmith's will named her cousin Frederic Greenhalge (defendant) as executor and residuary beneficiary, but its terms referenced a "memorandum" that would guide distribution of certain personal property. Nesmith kept a notebook, not formally executed as a will, listing specific items for specific people, including a painting she wanted to go to Clark (plaintiff). Greenhalge, acting as executor, initially recognized the notebook's validity but later gave the painting to someone else, and Clark sued to enforce the notebook's designation.
Whether an informal document not executed in the manner of a will may be incorporated by reference into a will if the will manifests an intent to incorporate the document and the document is sufficiently described.