## Facts

- Francis N. Edwards executed a will on June 23, 1981.
- On October 29, 1981—six days before his death—Edwards executed a new will leaving his entire estate to Richard Vance Freeman, a casual employee.
- Edwards died on November 3, 1981.
- The October 29, 1981 will was admitted to probate, with Citizens National Bank of Leesburg involved in the estate proceedings (as an appellee) and Freeman as the primary beneficiary.
- Edwards’s mother and sisters (the Edwardses) petitioned to revoke probate of the October 29 will and to establish probate of the June 23 will.
- The Edwardses alleged Edwards lacked testamentary capacity when he signed the later will because he suffered from organic brain syndrome and insane delusions.
- The Edwardses pointed to Edwards’s mistrust of his family and suspiciousness toward customers, arguing these were fixed false beliefs that affected his disposition.
- Freeman presented evidence that Edwards’s suspicions had factual support, including problems with shoplifting at the store and family behavior that Edwards viewed as invasions of his privacy and property.
- Medical and psychiatric experts for Freeman, including physicians who examined Edwards within days of the will’s execution, testified Edwards was of sound mind and showed no evidence of brain damage or psychosis.
- The attorney who drafted and supervised execution of the October 29 will testified Edwards was of sound mind and understood what the will did.
- The parties stipulated that, at the time of execution, Edwards understood the nature and extent of his property and knew the identities of his family members; the dispute centered on whether he understood the practical effect of the will as executed.
- After hearing testimony and receiving evidence, the trial court denied the petition to revoke probate, finding Edwards had testamentary capacity.
- The Edwardses appealed.

## Issues

1. Whether the trial court’s finding that Edwards had testamentary capacity when he executed the October 29, 1981 will was supported by competent, substantial evidence.
2. Whether Edwards’s suspicions toward family and customers amounted to an insane delusion that destroyed testamentary capacity or materially affected the testamentary disposition.

## Decision

- The Fifth District Court of Appeal affirmed the final judgment denying the petition to revoke probate.
- The court held there was competent, substantial evidence supporting the trial court’s determination that Edwards had testamentary capacity, including testimony from the drafting attorney and multiple medical and psychiatric witnesses.
- The court rejected the argument that Edwards’s distrust and suspiciousness necessarily constituted insane delusions, noting evidence that his beliefs had a basis in real events and relationships.

## Legal Principles

- Testamentary capacity in Florida requires a general ability to understand: (1) the nature and extent of one’s property, (2) one’s relationship to those who would naturally claim a substantial benefit, and (3) the practical effect of the will as executed.
- A will is not invalid merely because it is harsh, unusual, or disinherits close family; the focus is whether the testator possessed the required mental ability at execution.
- An insane delusion requires a fixed false belief without a reasonable factual basis, and it must materially affect the testamentary act to invalidate a will on that ground.
- When the parties stipulate to certain elements of capacity, the dispute may be limited to the remaining element(s), and the trial and appellate courts evaluate the evidence on that narrowed question.
- On appeal, a trial court’s finding on testamentary capacity will be upheld if supported by competent, substantial evidence; the appellate court does not reweigh conflicting testimony.

## Conclusion

The Fifth District affirmed the probate court’s refusal to revoke probate of Edwards’s October 29, 1981 will, concluding that competent, substantial evidence supported the finding that Edwards understood the practical effect of leaving his entire estate to Freeman and that the claimed suspicions about family and customers did not, on this record, establish an insane delusion that invalidated the will.


Edwards v. Citizens National Bank of Leesburg (In re Estate of Edwards), 433 So. 2d 1349 (1983)