Douglas G. Todd’s 1984 will is back in force. The Nebraska Supreme Court issued its opinion on October 30, 2026, rejecting a 2021 handwritten document that his partner, Judy Sheets, claimed left her his entire estate. The court upheld a lower court’s finding that the 2021 page is legally void under state law.
Sheets argued the document was valid because Todd dictated the terms to her, and he signed and dated it himself. She testified to a 40-year relationship, living together until his death in January 2025. But she admitted a critical detail: the actual distribution clauses were in her handwriting. That admission killed the case.
Nebraska Revised Statute Section 30-2328 is strict. For a holographic will to stand, the testator must write both the signature and the material provisions. Sheets tried to frame the note as a "joint will," suggesting her handwriting satisfied the requirement for both parties. The Supreme Court shut that down. A joint will is still two separate legal instruments. Since Todd’s assets are being distributed, only his handwriting counts.
Chadd B. Todd, Douglas’s son, argued that the 1984 document, which leaves everything to his brothers, was the only valid testament. The court agreed. It noted that allowing a third party to write the core terms would undermine the intent behind holographic will laws, which are meant to capture a testator’s personal, spontaneous intent without witnesses.
The ruling ends the probate battle in Lincoln County. Sheets loses the claim to the real estate and vehicles titled solely in Todd’s name. The estate proceeds to the sons.