Ariz. Rev. Stat. § 14-2502

Execution of paper wills; witnessed wills; holographic wills; testamentary intent

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A. Except as provided in sections 14-2503, 14-2506 and 14-2513, a paper will shall be:

1. In writing.

2. Signed by the testator or in the testator's name by some other individual in the testator's conscious presence and by the testator's direction.

3. Signed by at least two people, each of whom signed within a reasonable time after that person witnessed either the signing of the will as described in paragraph 2 of this subsection or the testator's acknowledgment of that signature or acknowledgment of the will.

B. Intent that a tangible medium or an electronic record constitutes the testator's will can be established by extrinsic evidence, including, for holographic wills under section 14-2503, portions of the document that are not in the testator's handwriting.

Notes of Decisions
Cited in 19 cases (2 in the last 5 years), 1978–2026 · leading case: In Re Estate of Jung
In Re Estate of Jung (2005) arizctapp · cites it 24× “¶ 9 Marc timely appealed. We have jurisdiction pursuant to Arizona Revised Statutes (“A.”
Gonzalez v. Satrustegui (1994) arizctapp · cites it 13× “”) section 14-2502 and that Nona could not take Frank’s estate as his surviving wife because Frank and Nona were not married.”
Matter of Estate of Johnson (1981) arizctapp · cites it 12× “The personal representative objected to the petition and filed a motion for summary judgment on the grounds that the instrument was invalid as a will, in that it was not attested by any witnesses as required by A.R.S. § 14-2502, [1] and did not qualify as a holographic will…”
Matter of Estate of Muder (1988) ariz · cites it 9× “WAS THE DOCUMENT A VALID WILL UNDER A.R.S. § 14-2502? The right to make a will did not exist at common law.”
Matter of Estate of Muder (1988) arizctapp · cites it 12× “Is the relevant document a validly executed will pursuant to A.R.S. § 14-2502? 2. Alternatively, is the document a valid holographic will executed pursuant to A.”
In Re The Matter Of The Estate Of: Bert W. Hook (2016) washctapp · cites it 2× “Ariz. Rev. Stat. Ann. § 14-2502 . As construed by an Arizona appellate court, the Arizona statute “does not preclude a witness from signing a testamentary document after the testator has died.”
Northern Trust Bank of Arizona, N.A. v. Goodman (2001) arizctapp · cites it 2× “No evidence then or now supports either contention.”
Zimmerman v. Allen (2011) arizctapp · cites it 5× “§ 14-2506 (2005) (“A written will is valid if executed in compliance with § 14-2502.”). A non-holographic will must be “[s]igned by the testator or in the testator’s name by some other individual in the testator’s conscious presence and by the testator’s direction,” and must be…”
Matter of Estate of Beaman (1978) arizctapp “Thus, the legislature has been consistent in requiring a writing in the same and related areas of the law.”
Matter of Estate of Krokowsky (1995) ariz “) § 14-2502 (1995). 2 . Heirs who are disinherited by will can no longer take by intestate succession.”
Lind v. Muder (1987) arizctapp · cites it 12× “Is the relevant document a validly executed will pursuant to A.R.S. § 14-2502? 2. Alternatively, is the document a valid holographic will executed pursuant to A.”
Bussberg v. Walker (2018) arizctapp · cites it 25× “When Bussberg petitioned to probate the will, Bradley's estranged son, Timothy Everson, objected, arguing neither Adamovich nor Walker was a valid witness under A.R.S. § 14-2502(A)(3). Everson claimed that he and Bradley's estranged daughter were Bradley's legal heirs.”
— Ariz. Rev. Stat. § 14-2502(A) — 2 cases
Zimmerman v. Allen (2011) arizctapp “§ 14-2506 (2005) (“A written will is valid if executed in compliance with § 14-2502.”). A non-holographic will must be “[s]igned by the testator or in the testator’s name by some other individual in the testator’s conscious presence and by the testator’s direction,” and must be…”
In Re Estate of Waterloo (2011) arizctapp
— Ariz. Rev. Stat. § 14-2502(A)(1) — 1 case
Goudeau v. Goudeau (2025) arizctapp
— Ariz. Rev. Stat. § 14-2502(A)(3) — 5 cases
In Re Estate of Jung (2005) arizctapp “¶ 9 Marc timely appealed. We have jurisdiction pursuant to Arizona Revised Statutes (“A.”
Zimmerman v. Allen (2011) arizctapp “§ 14-2506 (2005) (“A written will is valid if executed in compliance with § 14-2502.”). A non-holographic will must be “[s]igned by the testator or in the testator’s name by some other individual in the testator’s conscious presence and by the testator’s direction,” and must be…”
Bussberg v. Walker (2018) arizctapp “When Bussberg petitioned to probate the will, Bradley's estranged son, Timothy Everson, objected, arguing neither Adamovich nor Walker was a valid witness under A.R.S. § 14-2502(A)(3). Everson claimed that he and Bradley's estranged daughter were Bradley's legal heirs.”
Wagoner v. Aleman (2015) arizctapp
In Re Estate of Waterloo (2011) arizctapp
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