Erickson v. Erickson

Ronald Erickson executed a will two days before marrying Dorothy, leaving everything to her (or split with his children if she predeceased him), without including language addressing the contingency of his upcoming marriage; a state statute automatically revoked a pre-marital will unless it addressed that contingency, and the drafting attorney testified he believed no such express language was needed given the will's timing and terms relative to the wedding. Ronald's daughter Alicia (plaintiff) sought to exclude all evidence except the will, marriage certificate, and death certificate, arguing the statute automatically revoked the will; the trial court excluded broader evidence but still upheld the will as providing for the marriage contingency.