LaCroix v. Senecal
Connecticut Supreme Court
99 A.2d 115 (1953)
Celestine Dupre's original will left half her residuary estate to her nephew and the other half to Aurea Senecal (defendant); a later codicil revoked that residuary clause only to replace it with a nearly identical clause naming the same nephew (with a corrected name) and again leaving half to Senecal. But one of the codicil's attesting witnesses was Senecal's own husband, and state law voids any bequest to the spouse of an attesting witness so the witness's competency to testify isn't compromised by a personal stake in the gift - meaning the codicil's gift to Senecal was invalid. Dupre's niece (plaintiff), her heir at law, petitioned for probate; the probate court found the codicil's gift to Senecal void but nonetheless upheld the original will's gift to Senecal as valid, and the niece appealed.
Whether the doctrine of dependent relative revocation preserves a gift that a testator revoked by codicil, intending the codicil to be a valid substitute, when the codicil's substitute gift turns out to be invalid.