Coussee v. Estate of Efston

PRESIDING JUSTICE CAHILL

delivered the opinion of the court:

James Efston died leaving two testamentary documents, both purporting to be his will: one was executed in Illinois in 1975, the other in Greece in 1986. Petitioner Rosemary Coussee, a beneficiary under the 1975 will only, brought this action to construe the two wills. The trial court found the wills revealed one testamentary scheme and gave effect to both. Efston’s estate appeals, alleging the revocation clause in the 1986 will revokes the 1975 will. We agree and reverse.

James Efston, a Greek national, spent most of his adult life as…