Colley v. Estate of Dees

Summary

The Alabama Supreme Court affirmed a judgment entered after a jury trial upholding Sara Dees's 2012 will against challenges based on lack of testamentary capacity, undue influence, and fraud. The court held that the evidence created factual disputes for the jury, and it rejected challenges concerning bifurcation of claims, evidentiary rulings, and jury instructions.

Holdings

1. The trial court properly denied Colley's motion for judgment as a matter of law because the evidence, viewed favorably to the nonmovants, created disputed factual issues concerning Dees's testamentary capacity and whether Stephens exercised undue influence.
2. Colley was not entitled to relief concerning the judgment as a matter of law on his fraud claim because his appellate brief failed to discuss the elements of fraud or cite supporting authority.
3. The trial court did not abuse its discretion by bifurcating the will contest from claims concerning the power of attorney and Dees's financial accounts.
4. The trial court did not abuse its discretion by excluding evidence of Stephens's manslaughter conviction, violent reputation, and alleged violent or otherwise bad acts, while allowing evidence concerning his reputation for truthfulness.
5. The trial court's jury instructions and supplemental response to the jury's request for guidance did not warrant a new trial.
6. Colley did not establish that the trial judge's conduct toward his counsel prejudiced him or required reversal.

Questions Presented

1. Whether Colley was entitled to judgment as a matter of law on his claims that Dees lacked testamentary capacity or executed the will under Stephens's undue influence.
2. Whether the trial court erred by entering judgment as a matter of law for Stephens and Dees's estate on the fraud claim.
3. Whether the trial court abused its discretion by bifurcating the will contest from Colley's claims involving the power of attorney and Dees's financial accounts.
4. Whether the trial court abused its discretion by excluding evidence of Stephens's manslaughter conviction, violent reputation, and alleged prior bad acts.
5. Whether the jury instructions and the trial court's supplemental response to the jury's request for guidance required a new trial.
6. Whether the trial judge's alleged conduct toward Colley's counsel deprived Colley of a fair trial.

Disposition

affirmed