In re: Estate of Schappell

Summary

The Supreme Court of Maryland reversed the Appellate Court’s judgment and established a two‑step clear‑and‑convincing‑evidence test for equitable adoption when a decedent dies intestate with no surviving relatives, requiring proof of the decedent’s intent to adopt and that the decedent acted in accordance with that intent. The case was remanded to the Appellate Court with instructions to send the matter back to the Orphans’ Court for a jury‑trial determination of the petition to transmit issues.