On June 17, 2026, the Fourth Court of Appeals in San Antonio reversed a key portion of the trial court’s judgment in In the Matter of the Estate of Van L. “Slim” Crapps, Deceased, a will contest JW Carter Law litigated from the trial court through the court of appeals. Attorneys Jimmy Carter and Sarah Maldonado represented Van Kevin Christiansen, the decedent’s only son, in the appeal. Crapps executed a formal 29-page will in 2019, signing and initialing every page before two witnesses and a notary. After execution, he privately tore out the final three pages and orally declared the remaining 26 pages to be his will — without re-signing, without witnesses, and without any other legal formality. Following his death, those 26 pages were presented to the Medina County probate court and admitted as his will.
At a three-day jury trial, jurors found that Crapps had validly revoked his earlier 2015 will by destruction, but also found — contrary to the evidence — that the 2019 will had not been altered after he signed it. The jury sided with the will’s proponents, and the 26-page document remained probated.
On appeal, the Fourth Court agreed with Christiansen’s position: under Texas Estates Code § 253.002, a will, once properly executed, cannot be altered or partially revoked except with the same formalities required to execute a will in the first place. Because Crapps’s post-execution alteration was witnessed only by his wife, an interested party, and the document was never re-executed, the 26-page document could not stand as a valid will as a matter of law.
The court reversed the judgment and remanded the case for further proceedings. The decision underscores why Texas law requires specific formalities to make or change a will: to protect testators and their heirs from disputes over exactly this kind of after-the-fact alteration.
Note: the court remanded for further proceedings, so this matter is not yet fully resolved. We will share an update once the remand concludes.