Solon v. Slater

Summary

The court held that the Probate Court's decree admitting the decedent's will precluded the plaintiff from relitigating her claim that the defendants interfered with her expected inheritance, because the Probate Court necessarily determined that the will reflected the decedent's wishes and was not procured through undue influence. It held, however, that neither collateral estoppel nor res judicata barred the plaintiff's claim concerning interference with a proposed amendment to the antenuptial agreement, because that separate transaction and alleged conduct were not actually and necessarily adjudicated and could not have been litigated as a tort claim in the Probate Court. The judgment was therefore reversed in part and remanded for further proceedings on the contractual-interference claim.