Supreme Court of New Hampshire

In re Estate of Marie G. Dow

January 20, 2021

Summary

The court held that New Hampshire law governs the pretermitted-heir issue because the decedent was domiciled in New Hampshire at death and her will disposed only of personal property. Applying New Hampshire law, the court held that Christopher Dow was not named or sufficiently referred to in the will and therefore was a pretermitted heir entitled to his intestate share. The court reversed the probate division’s decision and remanded for further proceedings.