Mich. Comp. Laws » Michigan Compiled Laws / Chapter 700 / Act 386 of 1998
Michigan Compiled Laws

Mich. Comp. Laws § 700.2514 (2026)

Contracts concerning succession.

✓ current as of July 2026
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ESTATES AND PROTECTED INDIVIDUALS CODE


Act 386 of 1998


700.2514 Contracts concerning succession.

Sec. 2514.

    (1) If executed after July 1, 1979, a contract to make a will or devise, not to revoke a will or devise, or to die intestate may be established only by 1 or more of the following:

    (a) Provisions of a will stating material provisions of the contract.

    (b) An express reference in a will to a contract and extrinsic evidence proving the terms of the contract.

    (c) A writing signed by the decedent evidencing the contract.

    (2) The execution of a joint will or mutual wills does not create a presumption of a contract not to revoke the will or wills.

History: 1998, Act 386, Eff. Apr. 1, 2000

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Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1999–2024 · leading case: In Re VanConett Est., 687 N.W.2d 167 (Mich. Ct. App. 2004).
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In Re VanConett Est., 687 N.W.2d 167 (Mich. Ct. App. 2004). · cites it 2× “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
In Re Weber Est., 669 N.W.2d 288 (Mich. Ct. App. 2003). “See MCL 700.2514; In re McKim Estate, 238 Mich App 453, 456-459 ; 606 NW2d 30 (1999) (holding that an oral agreement to provide for someone in a will should only be considered if there is an actual will citing the contract or a writing to that effect signed by the decedent).”
In Re McKim Est., 606 N.W.2d 30 (Mich. Ct. App. 2000). “§ 700.2514; MSA 27.12514, which retains the present language without substantive changes.”
Pellie Mae Norton-Cantrell v. Anthony Bzura Trust Agreement (Mich. Ct. App. 2018). · cites it 17× “The probate court determined that MCL 700.2514, which provides that a contract to make a will or devise must be in writing, barred plaintiff’s claims.”
Heefner v. Cornell, 606 N.W.2d 30 (Mich. Ct. App. 1999). “Section 140 will be replaced by MCL 700.2514; MSA 27.12514, which retains the present language without substantive changes.”
Rau v. Leidlein, 687 N.W.2d 167 (Mich. Ct. App. 2004). · cites it 2× “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
In Re White Est., 677 N.W.2d 914 (Mich. Ct. App. 2004). “” The probate court stated that, “the will does not express a mutually acknowledged promise, consideration, or obligation between the testators that the will is irrevocable” and held that the will was joint and reciprocal, but not mutual.”
In Re Vanconett, Est., 708 N.W.2d 99 (Mich. 2006). “The parties shall include among the issues to be briefed: (1) whether MCL 700.2514 has displaced the case law that predated the adoption of the Estates and Protected and Individuals Code, MCL 700.”
P in Re E Earl Lyden Trust (Mich. Ct. App. 2024). · cites it 2× “He argued as follows: MCL 700.2514 requires a contract to make a will or devise to be in writing.”
— Mich. Comp. Laws § 700.2514(1) — 3 cases
In Re VanConett Est., 687 N.W.2d 167 (Mich. Ct. App. 2004). “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
Rau v. Leidlein, 687 N.W.2d 167 (Mich. Ct. App. 2004). “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
Pellie Mae Norton-Cantrell v. Anthony Bzura Trust Agreement (Mich. Ct. App. 2018). “The probate court determined that MCL 700.2514, which provides that a contract to make a will or devise must be in writing, barred plaintiff’s claims.”
— Mich. Comp. Laws § 700.2514(2) — 3 cases
In Re VanConett Est., 687 N.W.2d 167 (Mich. Ct. App. 2004). “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
In Re White Est., 677 N.W.2d 914 (Mich. Ct. App. 2004). “” The probate court stated that, “the will does not express a mutually acknowledged promise, consideration, or obligation between the testators that the will is irrevocable” and held that the will was joint and reciprocal, but not mutual.”
Rau v. Leidlein, 687 N.W.2d 167 (Mich. Ct. App. 2004). “] Pursuant to MCL 700.2514(1), a contract to make a will, not to revoke a will, or to die intestate may be established only by one or more of the following: (a) Provisions of a will stating material provisions of the contract.”
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