Nunnenman v. Estate of Grubbs
Arkansas Court of Appeals
374 S.W.3d 75 (2010)
Relevant factsFree
Grubbs named Nunnenman as his IRA beneficiary in 2003, then executed a 2005 will revoking prior wills and leaving his estate to his mother Shervena without mentioning the IRA; after his death, Shervena produced an undated handwritten note found in his Bible purporting to leave the IRA to her, and the trial court awarded her the IRA based on that note.
IssueFree
Whether, under Arkansas law, a testator can change the beneficiary of an IRA account by will if the will sufficiently identifies the policy and shows an intent to change the beneficiary.