In re Estate of Smith

Before committing suicide, Smith mailed checks and suicide notes to his sister and niece, then personally delivered two more checks and notes to his girlfriend and her sister (defendants) before returning home and killing himself; all four women cashed their checks. Smith's wife Jean (plaintiff), as administratrix of his estate, sued to recover the funds when the women refused to return them, and the trial court ruled the checks were valid gifts causa mortis; Jean appealed.