Richard E. Ivie, Jimmie R. Ivie, Ladonna Small, and Bernard Ivie, Respondents v. Arnold L. Smith and Sidney B…

Summary

The Supreme Court of Missouri affirmed a circuit court judgment voiding both of Patricia Watson's post-dementia trust amendments, her changes to bank-account, IRA, and CALSTRS-pension beneficiary designations, and her vehicle retitlings in favor of her husband Arnold Smith. Under the court-tried review standard, substantial evidence — chiefly a geriatric psychiatrist's testimony, credited over contrary witnesses, that Watson lacked testamentary capacity at all times after July 1, 2007, corroborated by extensive medical records — supported the incapacity findings, and the Court did not reach the circuit court's separate undue-influence conclusions because incapacity alone sustained the judgment. As a new rule, the Court held that beneficiary designations are matters of agreement governed by applicable law, so the higher contractual-capacity standard controls them; the circuit court's application of the lower testamentary standard was therefore non-prejudicial error, and a prior court of appeals decision drawing the opposite inference from Section 461.054 should no longer be followed.