Hamlin v. Jendayi - Case Brief

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Case Number: A167695M
Court: California Court of Appeal, First Appellate District, Division Three
Date Filed: 2025‑08‑31

Holding

The court held that heirs of a decedent who are disinherited by a revocable trust have standing to challenge the trust’s validity in probate court, and that the trial court’s determination—based on a statutory presumption of undue influence—was supported by substantial evidence; consequently, the trust was properly invalidated and the appellate judgment affirmed.

Narrative

Lead

When a terminally ill professor named a former student as the sole beneficiary of a revocable living trust, the professor’s estranged sisters turned to the probate court to contest what they alleged was a product of undue influence. The California Court of Appeal’s decision in Hamlin v. Jendayi crystallizes the appellate view that “intestate heirs” may sue to overturn a trust that disinherits them, and it reaffirms the robust evidentiary standards governing undue‑influence claims.

Procedural History

Dr. Laura Dean Head, a tenured professor at San Francisco State University, died in June 2013. Two months before her death she entered hospice care at the home of Zakiya Jendayi, a former student and longtime friend. While hospitalized, Dr. Head executed a living trust that named Jendayi as sole trustee and beneficiary, disinheriting her two sisters, Della Hamlin and Helaine Head. In May 2020 the sisters filed a petition in Alameda County Superior Court (Probate Division) to invalidate the trust on grounds of undue influence, lack of capacity, and alleged forgery. After a 17‑day bench trial, the trial court granted the petition, finding Jendayi had unduly influenced Dr. Head and ordering the trust assets transferred to the estate’s special administrator.

Jendayi appealed, arguing that the sisters lacked standing under Probate Code § 17200, which she read to limit contesting parties to trustees and beneficiaries. She also contended that the petition was time‑barred under the elder‑abuse provisions of the Probate Code. The appellate panel denied Jendayi’s petition for rehearing as untimely and, on its own motion, modified the opinion only to clarify that the respondents were “intestate heirs.” The judgment was affirmed.

Facts

The factual record is extensive. Dr. Head’s medical condition in early 2013 was dire: severe gastro‑esophageal cancer, renal failure, cirrhosis, profound malnutrition, and a recent hospitalization that left her unable to care for herself. Hospital records and a physician’s letter dated April 12, 2013, concluded that Dr. Head was “incapable of providing for her own needs for food, clothing, or shelter” and could not manage her financial affairs.

During this period Jendayi assumed the role of durable power of attorney (DPOA). She transferred Dr. Head’s vehicle title to herself, added herself to Dr. Head’s bank accounts, and arranged for an estate‑planning attorney, Elaine Lee, to draft the trust. Lee’s client‑intake form listed Jendayi—not Dr. Head—as the client, and Jendayi crossed out all fields concerning other potential beneficiaries, indicating a “N/A” response. The trust was executed on June 5, 2013, in Dr. Head’s hospital room, witnessed by a notary and two lay witnesses arranged by Jendayi.

Testimony from Dr. Head’s sisters painted a conflicting picture of their relationship with the decedent. Hamlin testified that Dr. Head had been estranged for years, citing a hospital social worker’s statement that Dr. Head expressly requested Jendayi as her health‑care agent and refused family contact. Helaine, however, described a close, ongoing relationship, noting frequent holiday visits and denying any estrangement. Jendayi described the relationship as “intimate, personal, special, physical, and sacred,” but offered no substantive evidence beyond photographs and correspondence.

Issues

  1. Standing: Whether heirs who are disinherited by a revocable trust possess standing to contest the trust in probate court under Probate Code §§ 17200 and 16061.7.
  2. Undue Influence: Whether the trial court’s finding of undue influence—based on the statutory presumption in Welfare and Institutions Code § 15610.70—was supported by substantial evidence.
  3. Procedural Timeliness: Whether the petition was barred by the elder‑abuse limitations in Probate Code §§ 16061.8 and 17200.

Holding and Reasoning

Standing

The appellate court rejected Jendayi’s narrow construction of § 17200, emphasizing that the statute’s language—“a trustee or beneficiary may petition the court”—does not expressly preclude other interested persons. The court turned to the broader statutory scheme, particularly § 16061.7, which mandates notice to “each heir of the deceased settlor” of the 120‑day contest period. The court reasoned that a reading that excludes heirs would render the notice requirement meaningless, a conclusion the court deemed “unacceptable.” Citing Arman v. Bank of Am., Estate of Sobol, and Olson v. Toy, the court affirmed that “interested persons” include heirs, and that the probate court possesses inherent discretion to confer standing under § 17206 when necessary to protect the estate’s integrity.

Undue Influence

The court applied the three‑prong test for the presumption of undue influence: (1) a confidential relationship, (2) active participation in procuring the instrument, and (3) an undue benefit. Substantial evidence supported each element:

  • Confidential Relationship: Dr. Head’s severe illness, dependence on Jendayi for medical decisions, and Jendayi’s role as DPOA created a relationship of trust and confidence. The court relied on Richelle L. v. Roman Catholic Archbishop and earlier cases (Estate of Cover, Estate of Rugani) to define the requisite vulnerability and reliance.

  • Active Participation: Although Lee testified she had not made major changes to the draft, the circumstantial evidence—Jendayi’s control of the intake form, her direction of the attorney, and her presence at the hospital execution—demonstrated direct involvement in shaping the final trust terms. The court cited Estate of Swetmann and Conservatorship of S.A. for the principle that participation may be inferred from a chain of causation.

  • Undue Benefit: Jendayi stood to receive the Randolph Avenue residence (valued at roughly $800,000) and a claim against the decedent’s mother’s estate—benefits that were “unwarranted, excessive, and unjustifiable” under Estate of Auen. The court noted the lack of any prior intent by Dr. Head to benefit Jendayi, the timing of the execution (hospital room, imminent death), and the absence of corroborating evidence of a genuine romantic partnership.

The appellate court affirmed the trial court’s application of the presumption, finding that the burden shifted to Jendayi and that she failed to rebut it by a preponderance of the evidence.

Timeliness

Because the sisters’ standing was upheld, the court did not need to address the alternative elder‑abuse limitation argument. The petition was timely under the 120‑day notice rule, and the appellate court noted that the petition was filed well within the statutory period after the trust’s execution.

Closing Analysis

Hamlin v. Jendayi provides a clear roadmap for practitioners confronting trust contests by disinherited heirs. First, the decision underscores that the Probate Code’s “interested person” language is to be read expansively; heirs are not merely peripheral parties but may be core litigants when a trust threatens to deprive them of their intestate share. Second, the opinion reaffirms the high evidentiary bar for overturning a trust on undue‑influence grounds, yet it illustrates how a combination of medical vulnerability, fiduciary control, and disproportionate benefit can satisfy the statutory presumption. Finally, the case highlights the importance of procedural precision—particularly the timing of petitions and the proper service of notice under § 16061.7—to avoid jurisdictional pitfalls.

Unresolved questions remain. The court left open whether an heir who was never a named beneficiary but who later acquires a contingent interest (e.g., through a pour‑over will) might invoke the same standing analysis, a point that Barefoot v. Jennings suggested but did not resolve. Moreover, the opinion skirts the issue of judicial estoppel when a party shifts its pleading strategy between statutory and common‑law bases—a tactical consideration that may surface in future elder‑abuse and trust‑contest litigation.

For California probate practitioners, Hamlin serves as a cautionary tale: meticulous documentation of a settlor’s capacity, the independence of counsel, and the absence of undue influence are essential to withstand the heightened scrutiny that heirs may now bring to the probate arena.

Referenced Statutes and Doctrines

  • Probate Code §§ 17200, 16061.7, 16061.8, 17000, 15800, 17206 – standing, notice, contest period, internal affairs, and court’s inherent powers.
  • Welfare and Institutions Code § 15610.70 – definition and factors of undue influence.
  • California Rules of Court 8.1105(b), 8.1110, 8.268(b)(1)(A) – certification for publication and rehearing deadlines.

Key Cases Cited

  • Barefoot v. Jennings, 8 Cal.5th 822 (2020) – standing under § 17200 and heirs.
  • Olson v. Toy, 46 Cal.App.4th 818 (1996) – heir standing to contest trusts.
  • Estate of Sobol, 225 Cal.App.4th 772 (2014) – flexible definition of “interested person.”
  • Arman v. Bank of Am., 74 Cal.App.4th 697 (1999) – standing requirements.
  • Richelle L. v. Roman Catholic Archbishop, 106 Cal.App.4th 257 (2003) – confidential relationship test.
  • Estate of Cover, 188 Cal 133 (1922); Estate of Rugani, 108 Cal.App.2d 624 (1952) – confidential relationship doctrine.
  • Estate of Swetmann, 85 Cal.App.4th 807 (2000) – active participation standard.
  • Estate of Auen, 30 Cal.App.4th 300 (1994) – definition of undue benefit.
  • Estate of Sarabia, 221 Cal.App.3d 599 (1990) – presumption of undue influence.
  • People v. Arias, 45 Cal.4th 169 (2008) – statutory construction principles.
  • Bucur v. Ahmad, 244 Cal.App.4th 175 (2016) – judicial estoppel.

End of brief.