## Facts

- Louisa F. Strittmater, an unmarried woman, died on December 6, 1944, leaving cousins as her closest blood relatives.
- On October 31, 1944, she executed a will leaving her entire estate to the National Woman’s Party.
- The cousins contested the will, alleging Strittmater lacked testamentary capacity because the will was the product of mental illness and insane delusions.
- Evidence included private writings expressing extreme hostility toward men and grotesque, hostile annotations about her deceased parents, reflecting a sharp reversal from earlier affection.
- Evidence also included episodes of violent or destructive behavior (e.g., destroying household items and killing a kitten) alongside testimony that she could appear normal and reasonable in public business dealings.
- Strittmater had been affiliated with the National Woman’s Party since 1925 and volunteered for it around 1939–1941; she had spoken of leaving her estate to the organization.
- Her long-time physician testified that Strittmater suffered from paranoia with a “split personality” presentation; there was no opposing medical testimony.
- The will was initially admitted to probate, later set aside by the Prerogative Court, and the proponent appealed.

## Issues

1. Whether Strittmater lacked testamentary capacity because an insane delusion or mental disease controlled the testamentary disposition.
2. Whether a testator who appears competent in ordinary affairs may nonetheless execute an invalid will when the dispositive scheme is caused by a delusional system.

## Decision

- The court affirmed the judgment denying probate of the will.
- It found Strittmater suffered from a paranoic mental disease with delusions, including an “insane hatred” directed at men.
- It concluded the bequest to the National Woman’s Party was caused by that mental disease rather than by rational testamentary judgment.
- Because the delusions produced the dispositive plan, Strittmater lacked testamentary capacity as to the will, and the estate passed by intestacy to her relatives.

## Legal Principles

- A testator may possess general competence to manage ordinary affairs yet lack testamentary capacity if an insane delusion controls the making of the will or a dispositive provision.
- An “insane delusion” that bears a causal connection to the testamentary disposition can invalidate the will, even where the testator appears outwardly normal in many interactions.
- Courts assess testamentary capacity by examining evidence of mental disease and whether the challenged disposition is the product of that disease, including medical testimony, writings, conduct, and the relationship between the delusional beliefs and the dispositive scheme.

## Conclusion

The court denied probate because uncontested medical evidence and corroborating writings and conduct supported a finding of paranoic delusions, and the court determined those delusions caused the testator to leave her entire estate to the National Woman’s Party rather than to her relatives, negating testamentary capacity for that disposition.


In re Strittmater’s Estate, 53 A.2d 205 (N.J. 1947)