Last minute estate plan changes often result in disputes. These disputes often involve situations where a elderly and newly widowed parent remarries or finds a new romantic partner quickly after their spouse’s death.
There are often questions by the adult children about whether the new spouse or partner gained influence over the parents’ finances, particularly if the decedent was isolated them from their family prior to death. There are also questions about changes to estate plans that disinherit the adult children in favor of the new spouse. Questions quickly turn to whether hese changes can be undone. This often involves claims of undue influence under Texas law.
The recent In re Estate of Lonnie K. Ledbetter, Jr., No. 02-25-00263-CV, 2025 WL 5644782 (Tex. App.—Fort Worth Dec. 11, 2025, no pet. h.) case provides an opportunity to examine how Texas courts evaluate claims of undue influence in the context of late-life remarriages.
Facts & Procedural History
Lonnie was a successful businessman who founded an isurance company with his brothers. He married his second wife, Saundra, in 1979. They remained married for forty-four years and created substantial wealth together. The wealth was held in trusts. The trusts were created for the benefit of Lonnie’s two adult children from his first marriage, Trace and Kendall, after both spouses died.
Saundra died in March 2023. Lonnie became “really depressed” afterward and began seeking companionship online. He met Tawni and, according to Tawni, they began dating in August 2023. Others suggested the relationship started later. On December 20, 2023, Tawni agreed to marry Lonnie. The next day, they married in Oklahoma at a ceremony officiated by Tawni’s son. Tawni admitted they married in Oklahoma because there was no waiting period for the marriage license.
Following the marriage, Lonnie made four new wills and changed the trust documents to disinherit Trace and Kendall. He appointed Tawni as successor trustee and devised eighty percent of his estate to her. Lonnie died in April 2025 at age eighty-two.
Trace and Kendall filed suit the day Lonnie died, alleging he lacked capacity and was unduly influenced by Tawni. The trial court granted a temporary injunction restraining Tawni from accessing estate and trust assets. Tawni appealed, arguing the injunction was impermissibly vague and overbroad.
The Three Elements of Undue Influence in Texas
Texas law requires proof of three elements to establish undue influence. First, there must be evidence of the existence and exertion of an influence. Second, the influence must have subverted or overpowered the testator’s mind at the time of execution. Third, the testator must have executed documents they would not have made but for the influence.
These elements are typically proven through circumstantial evidence. No single circumstance establishes undue influence, but several circumstances considered together may suffice. This case provides an example of how the courts apply the factors to a common fact pattern for these types of disputes.
1. Isolation and Control as Evidence of Influence
In this case, the court found sufficient evidence of the first element, existence and exertion of influence. The testimony showed Lonnie was “really depressed” after Saundra’s death and vulnerable to manipulation. He pursued a fictional “Nicole” online and proposed marriage to Tawni within months of meeting her.
After marriage, Lonnie’s relationships changed dramatically. There was testimony that Lonnie was “separated away from” others. Trace stated his access to his father was “greatly diminished.” Phone calls were blocked. When contact occurred, Tawni was present or listening. Cameras appeared in Lonnie’s bedroom. Tawni took over his finances—a departure from his prior independence.
2. Deceptive Behavior and Mental State
For the second element, the court considered whether Tawni’s influence overpowered Lonnie’s mind. Tawni invoked her Fifth Amendment right over twenty times at the hearing, including when asked if she lied to Lonnie about her age. She admitted fabricating her educational background, claiming she attended MIT and other universities when she had “no college background.”
A Michigan court had previously found Tawni “exaggerates on everything,” “prefabricates [and] manipulates,” and is “a con artist,” a “scam artist,” and a “psychopathic liar.” Audio recordings admitted at the hearing showed Tawni lying to Lonnie about serving in the Swedish military and selling her business for $90 million.
The court considered this evidence alongside Lonnie’s depression and simultaneous pursuit of two relationships during his vulnerable state.
3. Disinheritance as Unnatural Disposition
The third element required showing Lonnie executed documents he wouldn’t have absent Tawni’s influence. After marriage, Lonnie made numerous changes: appointing Tawni as successor trustee, creating four new wills, and disinheriting his children to benefit Tawni with eighty percent of his estate.
Texas courts view disinheritance of natural heirs as potentially unnatural, particularly without a reasonable explanation. The facts showed Lonnie had worked with Trace for thirty years and maintained close relationships with both children before meeting Tawni.
Evaluating Undue Influence Cases
The facts in Ledbetter follow a pattern that is frequently handled by Texas probate courts. From the family’s view, there is an elderly person grieving a long marriage becomes vulnerable to a new romantic partner who quickly isolates them from family and redirects their wealth. From the new partner’s view, there is a family that is aloof and neglectful and a desire for the elderly person to benefit them.
These cases can devastate families emotionally and financially.
This court case shows how the probate courts evaluate these situations. The analysis isn’t based on any single fact. Instead, circumstantial evidence builds across the three elements of undue influence: whether influence existed, whether it overpowered the decedent’s judgment, and whether the decedent made changes they otherwise wouldn’t have made.
In by what the court wrote in its opinion in this case, the isolation evidence proved particularly strong: blocked phone calls, constant supervision, cameras installed in Lonnie’s bedroom, and severed relationships with people he’d been close to for decades. Tawni’s pattern of deception—lies about her age, education, military service, and business dealings, combined with repeated invocations of the Fifth Amendment—demonstrated a willingness to manipulate for financial gain. The disinheritance raised obvious questions given that Lonnie had worked alongside Trace for thirty years and maintained close relationships with both children until meeting Tawni.
The Takeaway
This case shows how Texas courts evaluate cases with allegations of isolation, financial control, deceptive behavior, and rapid disinheritance in support of undue influence claims. When a new spouse appears to isolate an elderly person from family, take control of finances, and benefit from sudden estate plan changes, these circumstances together can establish a probable right to relief.
Do you need help with a probate matter in San Antonio or the surrounding area? We are San Antonio probate attorneys. We help clients navigate the probate process. Call today for a free confidential consultation, (210) 436-6601.
Our San Antonio Probate Attorneys provide a full range of probate services to our clients, including helping with probate litigation, including undue influence cases. Affordable rates, fixed fees, and payment plans are available. We provide step-by-step instructions, guidance, checklists, and more for completing the probate process. We have years of combined experience we can use to support and guide you with probate and estate matters. Call us today for a FREE attorney consultation.
Disclaimer
The content of this website is for informational purposes only and should not be construed as legal advice. The information presented may not apply to your situation and should not be acted upon without consulting a qualified probate attorney. We encourage you to seek the advice of a competent attorney with any legal questions you may have.
