C.F.R. » Title 25 » CHAPTER I—BUREAU OF INDIAN AFFAIRS, DEPARTMENT OF THE INTERIOR › SUBCHAPTER C—PROBATE › PART 15—PROBATE OF INDIAN ESTATES, EXCEPT FOR MEMBERS OF THE OSAGE NATION AND THE FIVE CIVILIZED TRIBES › Subpart A—Introduction

25 C.F.R. § 15.4

What are the requirements for a valid will?

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You must meet the requirements of § 15.3, date and execute your will, in writing and have it attested by two disinterested adult witnesses.

Notes of Decisions
Cited in 3 cases (1 in the last 5 years), 2016–2025 · leading case: Est. of Ducheneaux v. Ducheneaux (In Re Est. of Ducheneaux), 2018 SD 26 (S.D. 2018).
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Est. of Ducheneaux v. Ducheneaux (In Re Est. of Ducheneaux), 2018 SD 26 (S.D. 2018). · cites it 3× “Because the holographic writings did not comport with the attestation requirements of 25 C.F.R. § 15.4 , the Department held that the 2009 will controlled.”
Rios v. Lilley, 13 Am. Tribal Law 420 (2016). “25 C.F.R. § 15.4 (2008). Unlike the situation in In the Matter of the Estate of Lucille Snell, 4 Am.”
Est. Of Edwin Robert Goulter Jr (Wash. Ct. App. 2025). “See 25 C.F.R. § 15.4 . 2 No. 59317-3-II CP at 17.”
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