Validity of Holographic Wills

In Berry v.Trible, 626 S.E.2d 440 (Va. 2006), the court reiterated the criteria for holographic wills. The handwriting must stand alone if the document is to be a valid holographic will. The courtreversed the admission to probate of handwritten additions to a typewrittendocument because the handwritten language was “interwoven with the text, bothphysically and in sequence of thought” and the typewritten language thereforecould not be ignored as surplusage.