Arizona Revised Statutes

Ariz. Rev. Stat. § 14-2502 (2026)

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

✓ current as of May 2026

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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 Est. of Jung, 109 P.3d 97 (Ariz. Ct. App. 2005).

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Donovan v. Donovan (Ariz. Ct. App. 2026). · cites it 2× “A.R.S. §§ 14-2502 (paper wills), -2503 (holographic wills), -2518 (electronic wills).”

Goudeau v. Goudeau (Ariz. Ct. App. 2025). · cites it 5× “A.R.S. § 14-2502; accord First Credit Union v.”

Bussberg v. Walker, 420 P.3d 215 (Ariz. Ct. App. 2018). · 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.”

In Re The Matter Of The Est. Of: Bert W. Hook, 374 P.3d 215 (Wash. Ct. App. 2016). · 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.”

Wagoner v. Aleman (Ariz. Ct. App. 2015). · cites it 3× ““A will that does not comply with § 14-2502 is valid as a holographic will, whether or not witnessed, if the signature and the material provisions are in the handwriting of the testator.”

Zimmerman v. Allen, 250 P.3d 558 (Ariz. Ct. App. 2011). · 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…”

In Re Est. of Waterloo, 250 P.3d 558 (Ariz. Ct. App. 2011). · 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…”

In Re Est. of Jung, 109 P.3d 97 (Ariz. Ct. App. 2005). · cites it 24× “¶ 9 Marc timely appealed. We have jurisdiction pursuant to Arizona Revised Statutes (“A.”

N. Trust Bank of Arizona, N.A. v. Goodman, 23 P.3d 108 (Ariz. Ct. App. 2001). · cites it 2× “No evidence then or now supports either contention.”

Matter of Est. of Krokowsky, 896 P.2d 247 (Ariz. 1995). “) § 14-2502 (1995). 2 . Heirs who are disinherited by will can no longer take by intestate succession.”

Gonzalez v. Satrustegui, 870 P.2d 1188 (Ariz. Ct. App. 1994). · 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 Est. of McKay, 802 P.2d 443 (Ariz. Ct. App. 1990). · cites it 10× “§ 14-2504 also satisfies the execution requirements of A.R.S. § 14-2502. The document is type-written and consists of pages numbered one to four.”

Show all 19 citing cases →

— Ariz. Rev. Stat. § 14-2502(A) — 2 cases

Zimmerman v. Allen, 250 P.3d 558 (Ariz. Ct. App. 2011). “§ 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 Est. of Waterloo, 250 P.3d 558 (Ariz. Ct. App. 2011). “§ 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…”

— Ariz. Rev. Stat. § 14-2502(A)(1) — 1 case

Goudeau v. Goudeau (Ariz. Ct. App. 2025). “A.R.S. § 14-2502; accord First Credit Union v.”

— Ariz. Rev. Stat. § 14-2502(A)(3) — 5 cases

In Re Est. of Jung, 109 P.3d 97 (Ariz. Ct. App. 2005). “¶ 9 Marc timely appealed. We have jurisdiction pursuant to Arizona Revised Statutes (“A.”

Bussberg v. Walker, 420 P.3d 215 (Ariz. Ct. App. 2018). “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 (Ariz. Ct. App. 2015). ““A will that does not comply with § 14-2502 is valid as a holographic will, whether or not witnessed, if the signature and the material provisions are in the handwriting of the testator.”

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