Tennessee Code Annotated
Tenn. Code Ann. § 32-1-105 (2026)
Holographic will
✓ current as of May 2026
No witness to a holographic will is necessary, but the signature and all its material provisions must be in the handwriting of the testator and the testator's handwriting must be proved by two (2) witnesses.
Acts 1941, ch. 125, § 5; C. Supp. 1950, § 8098.5; T.C.A. (orig. ed.), § 32-105.
Notes of Decisions
Cited in 18
cases (2 in the last 5 years), 1984–2024 · leading case: In Re Est. of Boote, 198 S.W.3d 699 (Tenn. Ct. App. 2005).
In Re Est. of Boote, 198 S.W.3d 699 (Tenn. Ct. App. 2005). “[32] The statutory requirements for the execution and revocation of wills apply with equal force to codicils.”
Est. of Gladys Tipler, 10 S.W.3d 244 (Tenn. Ct. App. 1998). “” Tenn.Code Ann. §32-1-105 (1984). Since Testatrix’ holograph referred to Husband’s will, Testatrix’ heirs maintained that material provisions were not in Testatrix’ handwriting.”
In Re the Est. of Milam, 181 S.W.3d 344 (Tenn. Ct. App. 2005). “” 5 Tenn.Code Ann. § 32-1-105 (2003); see also Smith v.”
In Re Est. of Meade, 156 S.W.3d 841 (Tenn. Ct. App. 2004). “Tenn.Code Ann. § 32-1-105. In this case, the parties have stipulated that the handwritten document is the decedent's handwriting and that the requirements of the statute are met.”
Blackburn v. Blackburn, 253 S.W.3d 603 (Tenn. Ct. App. 2007). “The requirements for a valid holographic will are as follows: “No witness to a holographic will is necessary, but the signature and all its material provisions must be in the handwriting of the testator and the testator’s handwriting must be proved by two (2) witnesses.”
In Re: Est. of Joan Uhl Pierce, 511 S.W.3d 520 (Tenn. Ct. App. 2016). “Tenn. Code Ann. § 32-1-105 . In this case, the parties have stipulated that the handwritten document is the decedent’s handwriting and that the requirements of the statute are met.”
Boyd v. Boyd, 680 S.W.2d 462 (Tenn. 1984). “T.C.A. § 32-1-105 provides: “No witness to a holographic will is necessary, but the signature and all its material provisions must be in the handwriting of the testator and his handwriting must be proved by two (2) witnesses.”
In Re Est. of Glenn Allen Atkins (Tenn. Ct. App. 2020). “” (citing Tenn. Code Ann. § 32-1-105 )). Contestants ask this Court to distinguish between testimony as to knowledge of a testator’s signature versus testimony as to knowledge of a testator’s handwriting.”
In Re Est. of Micki D. Thompson (2021). “Nevertheless, the trial court denied the petition, holding that the writing did not satisfy the signature requirement of Tenn. Code Ann. § 32-1-105 because, inter alia, the decedent’s name, Micki D.”
In Re: The Est. of Elma Ward (Tenn. Ct. App. 2010). “Appellant, son of the decedent, appeals the trial court’s finding that the holographic will was valid, arguing that the document did not comply with the statutory requirements of Tenn. Code Ann. §32-1-105 . Finding that the presence of more than one signature, the location of…”
Lee v. Gilliam, 156 S.W.3d 841 (Tenn. Ct. App. 2004). “§ 32-1-105. In this case, the parties have stipulated that the handwritten document is the decedent’s handwriting and that the requirements of the statute are met.”
In Re: Last Will & Testament of Mary Theresse Erde (Tenn. Ct. App. 2017). “]” Because Tennessee law requires only two witnesses to testify as to the handwriting of a holographic will, see Tenn. Code Ann. § 32-1-105 (“[T]estator’s handwriting must be proved by two (2) witnesses.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.