Estate of Boyajian
The court held that under California Probate Code § 6120 a will may be revoked only by a physical alteration of the instrument or by a subsequent will that disposes of property, so a separate, notarized revocation document that does not itself dispose of any property is not a valid cancellation and therefore the 2018 document did not revoke the 2006 holographic will, which must be admitted to.
Date Filed: July 07, 2025
Case Name: Estate of Boyajian
Case Number: G063155
Court: California Court of Appeal, Fourth Appellate District, Division Three
(‘The Court decides whether a separate, notarized document can revoke a prior will by “cancellation” under Probate Code §\u202f6120. It holds that California law requires a physical alteration of the will to effect a cancellation and that a stand‑alone revocation document is not a “subsequent will” unless it also disposes of property; therefore the 2018 document does not revoke the 2006 holographic will and the earlier will must be admitted to probate. This ruling clarifies the strict formalities required for will revocation, guiding practitioners on how revocation must be manifested to be effective in California probate cases.’, ‘9c8e5191’)
This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.