## Facts

- Frank Honigman executed a will on April 3, 1956, about one month before his death, leaving most of his estate to collateral relatives, including relatives living abroad.
- The will gave the widow, Florence Honigman, only a life use of her minimum statutory share plus $2,500, with the principal passing at her death to the testator’s siblings and their descendants.
- Florence objected to probate, claiming the testator lacked testamentary capacity because he suffered from an insane delusion that she was unfaithful.
- Multiple disinterested witnesses testified that the testator repeatedly and publicly accused his wife of infidelity, often in obscene and abusive terms, and described implausible scenarios supporting the accusation.
- The record contained evidence of the testator’s serious illnesses and surgeries, but also indicated he generally functioned rationally apart from the fixation on his wife’s alleged infidelity.
- The drafting attorney testified that the testator explained his plan by stating that Florence was unfaithful, that she had enough money, and that he wanted his relatives to benefit.

## Issues

1. Whether the evidence permitted a finding that the testator held an insane delusion—an unwavering belief in supposed facts without reasonable basis—about his wife’s infidelity at the time of execution.
2. Whether there was sufficient evidence that the alleged delusion materially affected the dispositions in the will, thereby negating testamentary capacity.
3. Whether the Appellate Division erred in reversing a jury verdict against capacity and directing probate.

## Decision

- The Court of Appeals reversed the Appellate Division.
- The court reinstated the Surrogate’s decree denying probate and ordered a new trial.
- The court held that the record contained more than enough competent proof to submit the insane-delusion theory to the jury and to support the jury’s implicit finding that the delusion affected the will.
- The court concluded that the Appellate Division improperly displaced the jury’s resolution of fact questions supported by the evidence.
- A dissent argued that even a groundless belief did not necessarily amount to an insane delusion sufficient to defeat testamentary capacity.

## Legal Principles

- A testator may lack testamentary capacity if a specific insane delusion materially influences the testamentary act, even if the testator appears rational in other affairs.
- An “insane” or “morbid” delusion may be shown where a person persistently believes supposed facts that have no real existence, against all evidence and probability, and acts logically on the assumption that they exist.
- A will is not invalid merely because the testator holds unreasonable views; the delusion must be without reasonable factual basis and must causally affect the dispositions.
- When substantial evidence supports competing inferences about delusion and causation, those questions are for the factfinder, and an appellate court should not substitute its own findings for a supported jury verdict.

## Conclusion

The Court of Appeals held that a jury could find the testator’s persistent, baseless belief in his wife’s infidelity to be an insane delusion that motivated the will’s unfavorable treatment of the widow, requiring deference to the jury’s supported verdict and precluding an appellate directive admitting the will to probate.


In re Honigman’s Will, 8 N.Y.2d 244, 168 N.E.2d 676 (N.Y. 1960)