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Overall, the decision highlights how changes in inheritance law can affect ongoing family disputes. The appeals court concluded that differences in signatures and questions surrounding another version of the document were not sufficient to establish that Lloyd’s will failed to meet Louisiana’s revised legal requirements.
How the inheritance dispute began
In July 2024, the trial court separately recognised Louis E Lloyd Jr. as a forced heir. On January 31, 2025, the six children sought partial summary judgment, asking the court to declare the will absolutely null. The trial court granted their request on April 3, 2025, and later issued an amended judgment on August 12, 2026, formally declaring the will invalid.
Because of problems with its signatures and execution, the children also maintained that their father’s will was invalid. After examining the will, the judges found that it appeared to have been written, dated and signed by Lloyd, the two witnesses and the notary. Evelyn appealed, arguing that the children had failed to prove the document was legally defective. She also maintained that the burden of establishing the will’s invalidity rested with those challenging it, not with her. The revised law removed the requirement that the person making the will sign every separate page. It also eliminated the attestation clause as a condition of validity. Importantly, the legislation applied retroactively to pending claims, provided they had not already been decided through a final judgment. Since the children’s challenge was still pending when the amendments took effect, the appeals court held that the revised requirements applied. The evidence presented by the children did not establish that Lloyd had failed to sign the document or that it had not been properly executed. The court also noted that the existence of the separate ‘True Copy’ version did not prove that the actual will was invalid. Under Louisiana law, those challenging a notarial testament carry the burden of proving its invalidity, and the children had failed to meet that requirement.
In a November 6, 2026, ruling available on Justia, the Louisiana Court of Appeal, First Circuit, reversed a lower court judgment that had declared the October 20, 2015, will invalid and an absolute nullity. The Louisiana Court of Appeal reversed the August 12, 2026, amended judgment that had annulled Lloyd’s 2015 will. The appeals court found that the children had not provided sufficient evidence to establish that the document failed to meet the applicable legal requirements. It sent the case back to the trial court for further proceedings. It remanded the case for further proceedings and assessed the costs of the appeal against the six children. The ruling does not finally settle every issue concerning the estate or remove the separate forced-heirship determination. Instead, it overturns the judgment that had declared the will invalid, allowing the succession proceedings to continue.