Appeals Court Reinstates Louisiana Lloyd Will
A Louisiana appeals court reversed an annulment of a 2015 will left by Louis Edward Lloyd Sr., which had been challenged by six of his nine children.
Updated on Nov. 11, 2026 in Legislative Policy
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The Louisiana Court of Appeal, First Circuit, reversed the annulment of Louis Edward Lloyd Sr.'s 2015 will, which left all his property to Evelyn Robertson Lloyd. The appeals court found the will met the revised legal requirements and that the challenging children failed to prove it was invalid.
Why it matters
The ruling upholds a will against challenges from six children and clarifies how Louisiana's Act 30 of 2025, which removed the requirement that a testator sign every page of a notarial will, applies to pending cases. The decision also reinforces the legal presumption that a testament is valid.
The appeals court reversed the August 12, 2026 amended judgment that annulled the will and ordered the six children to pay the costs of the appeal. Act 30 of 2025 took effect August 1, 2025, and was applied because the case was pending at that time.
The players
Court of Appeal of Louisiana, First Circuit
The intermediate appellate court for the Louisiana parishes that reviewed and reversed the annulment of the Lloyd will.
Act 30 of 2025
A Louisiana law that removed the requirement that a testator sign every page of a notarial will, effective August 1, 2025.
The details
Lloyd died in 2021, and Evelyn Robertson Lloyd petitioned in December 2021 to be recognized as sole legatee; the trial court initially did so. Six children challenged the will in October 2022, arguing it was invalid because Louis E. Lloyd Jr. was totally disabled and qualified as a forced heir, and questioning signatures that appeared in printed form on the first page and cursive on the second. The notary, Linda E. Hodge, testified that Lloyd read the document and signed it before two witnesses.
Timeline
2015: Lloyd signed the will leaving his property to Evelyn Robertson Lloyd.
2021: Louis Edward Lloyd Sr. died.
December 2021: Evelyn Robertson Lloyd petitioned to be recognized as sole legatee.
October 2022: Six of Lloyd's children challenged the will.
November 6: The First Circuit delivered its judgment reversing the annulment.
Legislative Policy Context
The ruling applies Louisiana Act 30 of 2025, which removed the every-page signature requirement for notarial wills, to a case pending when the law took effect on August 1, 2025. This extends the statute's practical reach to wills challenged after its enactment, not only those executed afterward.
Louisiana residents who hold notarial wills may find the every-page signature rule no longer applies after August 1, 2025, though the ruling itself applies only to this estate. Anyone contesting a will in the state should expect the presumption of validity to weigh heavily against a challenger.
The takeaway
Estate disputes often turn on procedural formalities, and changes to those rules can reshape outcomes even in cases already underway. Reviewing a will's signing and notarization details with an attorney can prevent costly challenges later.
Further reading
For more on how state lawmakers shape rules like these, see Legislative Policy coverage.
Source note: This article includes information reported by The Times of India.
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