Undue Influence In Wills Cases In Arkansas

In order to void a will, undue influence must be directed toward procuring a will in favor of particular parties. In re Estate of Davidson, supra; Rose v. Dunn, supra. However, a beneficiary of a will does not exercise undue influence over the testator merely because the beneficiary influenced him in the ordinary affairs of life or because the beneficiary was in a confidential relationship with the testator when he executed his will. See Gross v. Young, 242 Ark. 604, 611, 414 S.W.2d 624, 628 (1967) (quoting Boggianna v. Anderson, 78 Ark. 420, 94 S.W. 51 (1906)). Accord In re Estate of Davidson, supra; Reddoch v. Blair, 285 Ark. 446, 688 S.W.2d 286 (1985); Hodges v. Cannon, supra. : Reddoch v. Blair, supra; Rosenbaum v. Cahn, 234 Ark. 290, 351 S.W.2d 857 (1961). In addition, a testator's decision to favor a person with whom he had developed a close and affectionate relationship is not, of itself, proof that the favored beneficiary procured the will by undue influence. See Reddoch v. Blair, supra; Abel v. Dickinson, supra.