Eyford v. Nord - Case Brief

Eyford v. Nord

Case Number: A157962

Court: Cal. Ct. App.

Date Filed: 2021-03-18

Case Brief – Eyford v. Nord

Court: COURT OF APPEAL OF THE STATE OF CALIFORNIA
Date: 2025-09-03
Case Number: A157962
Disposition: Judgment affirmed; respondents awarded costs on appeal.

Holding

The court held that the trial court did not err in finding that Catherine “Kay” Pearson lacked a mental health disorder with delusional symptoms at the time she executed her 2016 trust, and therefore the trust— which disinherited the appellants—remains valid under Probate Code § 6100.5(a)(2).

Narrative

Lead – In a tightly contested probate dispute, the California Court of Appeal affirmed a lower‑court ruling that a 90‑year‑old decedent’s charitable trust, which left her $2 million estate to St. Jude Children’s Research Hospital and disinherited her grandchildren, was executed with sufficient testamentary capacity. The decision clarifies the application of Probate Code § 6100.5 to trusts and underscores the high evidentiary bar plaintiffs face when alleging delusional incapacity.

Procedural History – Shannon Eyford and Erin Johnson (the appellants) filed a petition in Napa County Superior Court in April 2017 seeking to invalidate Kay Pearson’s February 24, 2016 revocable living trust on the ground that Kay suffered a mental health disorder with delusional symptoms that caused her to disinherit them. The trial court denied the petition, concluding that the evidence did not establish a delusion‑induced lack of capacity. The appellants appealed, arguing that the trial court erred in its factual findings and in its interpretation of § 6100.5(a)(2). The Court of Appeal reviewed the case de novo on the statutory question but applied the substantial‑evidence standard to the factual determinations.

Facts – Kay Pearson, a widowed former senior‑living resident, executed a trust naming St. Jude as the sole beneficiary and expressly excluding her son and her two granddaughters, Eyford and Johnson. The trust was signed on February 24, 2016 after a series of rapid, overlapping meetings with three different attorneys (James Watson, then Lori Hunt) and her accountant, Joan Sturges. Between October 2015 and early 2016 Kay experienced a brief episode of delirium secondary to a urinary‑tract infection and a hospitalization, during which she displayed confusion, paranoia, and false accusations against the appellants. Witnesses reported that Kay’s demeanor fluctuated between “good days” and “bad days,” but that on the day she signed the trust she appeared clear‑headed, expressed a coherent rationale for the charitable gift (honoring her late husband Bob’s love of “sick babies”), and denied any coercion.

The appellants presented two lines of proof: (1) a pattern of false beliefs—Kay repeatedly alleged that the grandchildren were stealing cash, plotting to have her declared incompetent, and even trying to push her off a balcony; (2) expert testimony from Dr. Spar (psychiatrist) that Kay’s delusional state persisted into February 2016. The respondents countered with expert testimony from Dr. Angelone (neuropsychologist) and Dr. Cheyette (psychiatrist) that Kay suffered only mild cognitive impairment and a transient delirium that resolved before the trust execution. Additional testimony from Kay’s long‑time internist, oncologist, accountant, and friends corroborated the view that Kay was lucid in the weeks surrounding the signing.

Issues – The appeal turned on two intertwined questions: (1) whether § 6100.5(a)(2) applies to a revocable trust that functions as a testamentary instrument; and (2) whether the evidence established that Kay possessed a mental health disorder with delusional symptoms that caused the disinheritance, thereby rendering the trust invalid.

Statutory Framework – Probate Code § 6100.5(a)(2) declares a testator incompetent if, at the time of execution, the individual suffers from a mental health disorder whose symptoms include delusions or hallucinations that “result in the individual’s devising property in a way that, except for the existence of the delusions or hallucinations, the individual would not have done.” The Court reiterated Andersen v. Hunt (2011) 196 Cal.App.4th 722, holding that the statute’s language extends to trusts and trust amendments that “closely resemble a will or codicil” in effect. The Court further emphasized that the statute requires both a qualifying mental health disorder and delusional symptoms that are causally connected to the testamentary act.

Court’s Reasoning –

Applicability to Trusts – Citing Andersen and Lintz v. Lintz (2014), the Court affirmed that a trust that reallocates the entire estate to a single charitable beneficiary is functionally equivalent to a will for purposes of § 6100.5. Accordingly, the statutory test applies.
Standard of Review – The Court rejected the appellants’ call for de novo review of the factual findings, noting that the trial court’s determination rested on “substantial evidence” concerning Kay’s mental condition—a mixed‑fact issue involving expert testimony. Under California law, appellate review of such factual findings is limited to whether the evidence is substantial, not whether the trial court weighed it correctly.
Presence of a Mental Health Disorder – The Court found that the expert testimony establishing a mental health disorder was lacking. Dr. Angelone testified that mild cognitive impairment is not a DSM‑5 mental disorder, and Dr. Cheyette agreed that delusions are “very rarely” associated with such impairment. Both experts described Kay’s delirium as a transient, infection‑related episode that resolved with treatment. No evidence showed a persistent disorder (e.g., dementia, psychotic disorder) at the time of the trust signing.
Existence and Causation of Delusions – Even assuming Kay harbored false beliefs about the appellants, the Court held that those beliefs were tethered to factual circumstances and therefore did not rise to the level of delusions. The Court relied on Estate of Putnam (1934) 1 Cal.2d 162, which defines a delusion as a belief “without evidence” that the testator adheres to “against all evidence and argument.” The trial record demonstrated that Kay’s accusations—while unfounded—were rooted in observable events (e.g., recent hospitalization, the presence of the grandchildren in her home) and were not “imagined facts” divorced from reality. Moreover, the Court noted that the trial court expressly rejected the notion that the single belief that the appellants “wanted her out of the way to get her money” was a delusion, and that this analysis was representative of the broader factual context.
Temporal Proximity – The Court emphasized that the alleged delusional episode occurred in October 2015, whereas the trust was executed in February 2016 after Kay’s health had stabilized. Expert testimony confirmed that delirium typically resolves within days to weeks, and no evidence indicated a relapse. Accordingly, any delusional symptoms were not “operational” at the moment of execution.
Policy Considerations – While acknowledging the emotional weight of the case, the Court reiterated that the statutory language is clear: “the burden is always upon the contestants of the will to show affirmatively…by a preponderance of the evidence” that the testator lacked capacity. The Court declined to expand the definition of “delusion” to include merely unreasonable or prejudiced beliefs, warning that such an expansion would render the mental‑disorder requirement surplusage.

Disposition – The appellate court affirmed the trial court’s judgment, concluding that the petition to invalidate the trust failed because the appellants did not meet the statutory burden of proving a mental health disorder with delusional symptoms at the time of execution. Respondents were awarded costs on appeal.

Closing Analysis – Eyford v. Nord provides a definitive statement on two fronts. First, it confirms that Probate Code § 6100.5 applies to revocable trusts that function as testamentary instruments, aligning with Andersen and extending the protective scope of the statute beyond traditional wills. Second, and perhaps more consequentially, the decision underscores the rigorous evidentiary threshold required to prove delusional incapacity. The Court’s reliance on the “substantial evidence” standard and its strict interpretation of “delusion” signal to probate litigators that expert testimony must establish a clinically recognized mental disorder and a causal link between that disorder and the testamentary act. Mere episodic confusion, transient delirium, or a constellation of unfounded accusations will not satisfy the statutory test.

Unresolved issues linger, however. The opinion did not address whether a single false belief, if proven delusional, could suffice to invalidate a trust when other beliefs are deemed reasonable—a question that may surface in future challenges involving mixed‑evidence scenarios. Additionally, the Court’s reliance on the Andersen extension leaves open the possibility of further doctrinal refinement concerning the boundary between trusts and wills for capacity challenges. Practitioners should therefore continue to obtain comprehensive neuropsychological evaluations when drafting or contesting late‑life estate plans, especially when the testator exhibits any signs of cognitive fluctuation.

Overall, Eyford reinforces California’s longstanding presumption of testamentary capacity and clarifies that overturning a well‑documented, charitable trust demands more than anecdotal evidence of paranoia; it requires a medically substantiated, ongoing mental disorder that directly motivated the dispositive act.

Referenced Statutes and Doctrines

Probate Code § 6100.5(a)(2) – Mental health disorder with delusional or hallucinatory symptoms rendering a testator incompetent.
Probate Code § 6100.5(a)(1) – General presumption of capacity.
Doctrine of Testamentary Capacity – Presumption of capacity; burden of proof on challenger (Estate of Sarabia, 1990).
Delusion Definition – Estate of Putnam (1934) 1 Cal.2d 162; Estate of Alegria (1948) 87 Cal.App.2d 645.
Standard of Review – Substantial evidence for factual findings (Cochran v. Rubens, 1996); de novo for pure statutory questions (Harustak v. Wilkins, 2000).
Andersen v. Hunt, 196 Cal.App.4th 722 (2011) – Extension of § 6100.5 to trusts resembling wills.
Lintz v. Lintz, 219 Cal.App.4th 1255 (2014) – Trust amendments that effectively re‑devise estate.
Estate of Hansen, 38 Cal.App.2d 99 (1940) – Weight of attorney‑witness testimony.
Goodman v. Zimmerman, 25 Cal.App.4th 1667 (1994) – Interpretation of “delusion” requirement.
Muzquiz v. City of Emeryville, 79 Cal.App.4th 1106 (2000) – Statement of decision need not address every issue.
People v. Mowatt, 56 Cal.App.4th 713 (1997) – Appellate role limited to substantial evidence.
Doolittle v. Exchange Bank, 241 Cal.App.4th 529 (2015) – Heavy burden on capacity challengers.