A disagreement over a father’s signature on his will turned into a lengthy inheritance dispute in Louisiana, after six of his nine children challenged a document that left his estate to his surviving wife. The children questioned whether the will had been properly signed and witnessed, arguing that the difference between the printed name on its first page and the cursive signature on its second page made it legally invalid.In a November 6, 2026, ruling available on Justia, the Louisiana Court of Appeal, First Circuit, reversed a lower court judgment that had declared the October 20, 2015, will invalid and an absolute nullity. The appeals court found that the children had not provided sufficient evidence to establish that the document failed to meet the applicable legal requirements. It sent the case back to the trial court for further proceedings.
How the inheritance dispute began
Louis Edward Lloyd Sr. died on July 19, 2021, leaving behind his wife, Evelyn Robertson Lloyd, and nine children. Three of the children were born during his marriage to Evelyn, while the remaining six were from another relationship. On December 1, 2021, Evelyn filed a petition asking the court to recognise her as the sole legatee under her husband’s October 2015 will. The document left all his separate and community property to her. On December 7, 2021, the trial court granted her petition and placed her in possession of the estate.However, six of Lloyd’s children challenged the arrangement in October 2022. They filed a petition seeking to annul the probated will and reopen the succession proceedings. Among their arguments was that their brother, Louis E Lloyd Jr., was totally disabled and qualified as a forced heir under Louisiana law.In July 2024, the trial court separately recognised Louis E Lloyd Jr. as a forced heir. The children also maintained that their father’s will was invalid because of problems with its signatures and execution.
Why the children challenged the signatures
The main dispute concerned the way Lloyd’s name appeared on the two-page document. The children argued that his name was printed on the first page, while a cursive signature appeared on the second page. They claimed that the difference meant the will did not satisfy the legal requirements for a valid notarial testament.They also questioned whether the document had been signed in the presence of a notary and two witnesses. Their concerns extended to another version of the will, which carried a ‘True Copy’ stamp and contained differences in the names of some family members.The notary who prepared the document, Linda E Hodge, testified that Lloyd had read the will and signed it in front of two witnesses, Marsha Strickland and Eugene Hodge Sr. She identified the separate ‘True Copy’ version and explained that it contained typographical errors, including an incorrect name for one of Lloyd’s children. However, Hodge could not clearly remember why the document had been stamped ‘True Copy’ or whether the witnesses remained present while she corrected the errors and prepared the final version.
Why the appeals court reversed the decision
On January 31, 2025, the six children sought partial summary judgment, asking the court to declare the will absolutely null. The trial court granted their request on April 3, 2025, and later issued an amended judgment on August 12, 2026, formally declaring the will invalid. Evelyn appealed, arguing that the children had failed to prove the document was legally defective. She also maintained that the burden of establishing the will’s invalidity rested with those challenging it, not with her.The appeals court examined Louisiana’s Civil Code and an important legislative change that took effect on August 1, 2025. The revised Article 1576 simplified the requirements for notarial wills. Under the amended provision, a will must be written, dated and executed before a notary in the presence of two witnesses, with signatures from the testator, both witnesses and the notary.The revised law removed the requirement that the person making the will sign every separate page. It also eliminated the attestation clause as a condition of validity. Importantly, the legislation applied retroactively to pending claims, provided they had not already been decided through a final judgment. Since the children’s challenge was still pending when the amendments took effect, the appeals court held that the revised requirements applied.After examining the will, the judges found that it appeared to have been written, dated and signed by Lloyd, the two witnesses and the notary. The evidence presented by the children did not establish that Lloyd had failed to sign the document or that it had not been properly executed. The court also noted that the existence of the separate ‘True Copy’ version did not prove that the actual will was invalid. Under Louisiana law, those challenging a notarial testament carry the burden of proving its invalidity, and the children had failed to meet that requirement.
What happens next
The Louisiana Court of Appeal reversed the August 12, 2026, amended judgment that had annulled Lloyd’s 2015 will. It remanded the case for further proceedings and assessed the costs of the appeal against the six children. The ruling does not finally settle every issue concerning the estate or remove the separate forced-heirship determination. Instead, it overturns the judgment that had declared the will invalid, allowing the succession proceedings to continue.Overall, the decision highlights how changes in inheritance law can affect ongoing family disputes. The appeals court concluded that differences in signatures and questions surrounding another version of the document were not sufficient to establish that Lloyd’s will failed to meet Louisiana’s revised legal requirements.
