The applicant sought to admit the deceased's suicide note into probate as a holograph will.
The deceased had a history of heavy alcohol and drug use and wrote the profanity-laced note shortly before taking his own life, attempting to disinherit his spouse.
The court found that suspicious circumstances existed, shifting the burden to the applicant to prove testamentary capacity.
Given the evidence of the deceased's intoxication and the lack of a definitive expert opinion on capacity, the court concluded the applicant failed to meet the burden.
The application to admit the note as a holograph will was dismissed.