CALIFORNIA’S STATUTORY WILL NEEDS AN UPDATE TO KEEP UP WITH DUKE
By Anne M. Rudolph and Ralph E. Hughes*
California’s Statutory Will1 needs to be updated. The current California Statutory Will form became law in 1991, when Pete Wilson was governor of California and Nirvana came out with "Smells Like Teen Spirit." In those days, any potential reformation of a will in California was governed by Estate of Barnes.2 In Estate of Barnes, California’s Supreme Court affirmed the established rule that extrinsic evidence could not be used to reform a will that was unambiguous on its face.