Petitioners appealed from the admission of the decedent’s will to probate following a formal proof-of-will issue. On appeal, petitioners argued that the decision to admit the will was against the manifest weight of the evidence because respondents allegedly failed to establish that the will was executed in substantial compliance with the Electronic Wills, Electronic Estate Planning Documents, and Remote Witnesses Act. The appellate court affirmed, applying a substantial-compliance framework to determine that the essential purposes of the Act were achieved where the remote execution was sufficiently documented and observed to provide a reliable basis for determining proper will execution and that there was no evidence that established a deviation that compromised the identity of the participants, the authenticity of the execution, or the integrity of the testamentary instrument. (LYLE and OCASIO, concurring)
Illinois Appellate Court
Civil Court
Electronic Wills Act