Friedman v. Hannan

ADKINS, Judge.

In this case we interpret Section 4-105(4) of Md.Code (1974, 2001 ReplVol.) Estates & Trusts Article (“ET”), which directs that , provisions in a will “relating to the spouse” be revoked upon divorce from that person. We hold that the automatic revocation provision of ET Section 4-105(4) is not limited to bequests to a former spouse, and may include bequests to a former spouse’s family members. A court should utilize the terms of the will and circumstances surrounding its execution to determine whether a bequest “relat[es] to the spouse” within the meaning of Section 4-105(4),

On…