New Jersey Will Contests

New Jersey recognizes two ways to challenge a will, and each carries its own clock. Before the will is admitted, a caveat filed with the County Surrogate stops that office from acting. After probate, Rule 4:85-1 sets four months to file a complaint in the Superior Court, or six months for a person who lived outside New Jersey when probate was granted.

The worry behind this search is rarely a legal one. A parent rewrote a will late, a new caregiver appeared, a signature looks wrong, and the family wants to know whether anything can be done. New Jersey answers narrowly. Disappointment is not a ground. A challenge has to rest on capacity, undue influence, fraud, forgery, a signing that missed N.J.S.A. 3B:3-2, or a revocation, and it has to land inside a short window. This page walks the caveat, the four-month complaint, the grounds, the no-contest rule, the separate deadline for a revocable trust, and what a contest does to the money. It is general information, not legal advice.

Read this next to the New Jersey will requirements guide, which sets out the execution rules a contest attacks, and the New Jersey probate guide for how the Surrogate and the Probate Part split the work. To find the office holding the file, use the New Jersey County Surrogate directory.

The Caveat Stops the Surrogate Before Probate

A caveat is a written objection filed with the County Surrogate before that office enters judgment admitting the will. It is short, cheap, and blunt. Rule 4:82 says the Surrogate's Court shall not act in any matter in which a caveat has been filed with it before the entry of its judgment, unless a Superior Court order or judgment authorizes it and then only in accordance with that order. The same rule pulls the Surrogate out of five other situations: a doubt on the face of a will, a lost or destroyed will, an application to admit a handwritten writing intended as a will under N.J.S.A. 3B:3-2(b) or N.J.S.A. 3B:3-3, an application for an administrator pendente lite, a dispute before the Surrogate on any matter, and a case the Surrogate certifies to be of doubt or difficulty.

Once the Surrogate is out, the case has to be started somewhere. Rule 4:84-1 says any person in interest may file a complaint and apply for an order requiring the other interested parties to show cause why the relief should not be granted. That action belongs to the Superior Court of New Jersey, Chancery Division, Probate Part.

Timing leaves a narrow opening. N.J.S.A. 3B:3-22 bars admission of any will to probate until after 10 days from the death of the testator, while letting the complaint, the witness depositions, and the executor's qualification happen earlier. County Surrogates describe the same rule on their own sites as the eleventh day. So an executor cannot walk in the morning after a funeral and close the matter, and a family that already suspects a problem has a short head start before the caveat route closes.

The filing fees are set by statute and identical in all 21 counties. N.J.S.A. 22A:2-30 charges $25 to file or withdraw a caveat, $175 for the first paper filed in an action in the Superior Court, Chancery Division, Probate Part, and $110 for the first answering paper filed by anyone other than the plaintiff. Those numbers cover the paperwork, not the lawyer.

After Probate You Have Four Months, Six If You Lived Out of State

Most people find out too late for a caveat. Rule 4:85-1 is the path after the Surrogate has already acted. Where a will has been probated or letters testamentary, of administration, guardianship, or trusteeship have issued, any person aggrieved by that action may file a complaint stating the basis for the relief sought and obtain an order requiring the personal representative, guardian, or trustee to show cause why the probate should not be set aside or modified or the grant of letters vacated. The complaint and order to show cause are served under Rule 4:67-3, and other interested people may move to intervene.

Then comes the part that decides most New Jersey cases before anyone argues the facts. The complaint has to be filed within four months after probate or after the grant of letters. If the aggrieved person lived outside New Jersey when probate or letters were granted, the period is six months.

Two escape hatches exist and neither is generous. Rule 4:85-2 lets the court extend the four-month or six-month period by no more than 30 days, and only on a showing of good cause and the absence of prejudice. Rule 4:85-1 also carves out relief sought under Rule 4:50-1(d), (e), or (f) or under Rule 4:50-3, the provision its own text labels fraud upon the court, and puts those claims on a reasonable-time standard instead of a fixed count. Neither is a substitute for the fixed period. The probate date sits in the Surrogate's record, and it is the date the count runs from.

There is one more late route, and it belongs to a document rather than a grievance. Rule 4:85-3 handles the after-discovered will. Where administration was granted and a will later turns up, or a later will surfaces after an earlier one was probated, the person offering it files a complaint and moves without notice for an order requiring all interested persons to show cause why the new will should not be probated. That complaint goes in the county where the original probate or administration was granted.

The Notice of Probate Can Eat Half Your Window

Here is the trap that catches New Jersey families. The four months run from the date of probate, and the letter announcing that probate happened can arrive nearly two months later.

Rule 4:80-6 gives the personal representative 60 days after the probate of a will to mail each beneficiary under the will, plus the people identified by Rule 4:80-1(a)(3), a written notice that the will has been probated, where and when it was probated, the name and address of the personal representative, and a statement that a copy of the will will be furnished on request. Proof of mailing goes to the Surrogate within 10 days after that. When names or addresses cannot be found by reasonable inquiry, notice is published in a county newspaper instead. A charitable gift adds notice and a copy of the will to the Attorney General.

Nothing in that rule moves the R. 4:85-1 deadline. A beneficiary who waits for the mail, reads the notice on day 55, and then spends three weeks deciding has burned most of the window. The postmark on that notice is not what the rule measures from. The Surrogate's record of the probate date is. The New Jersey probate timeline guide lays the rest of the estate calendar next to this one.

Who Can Contest a New Jersey Will

Rule 4:85-1 opens the door to any person aggrieved by the probate or by the grant of letters. New Jersey courts read that the same way they read the class of people entitled to file a caveat: someone who would be injured by the probate of the will. The practical test is financial, meaning whether the person would take more if the will fell.

• Heirs who would inherit without the will. If the will were set aside and no earlier will survived, the estate would pass under New Jersey intestate succession, starting with N.J.S.A. 3B:5-3 for a surviving spouse, civil union partner, or domestic partner and N.J.S.A. 3B:5-4 for everyone else in line.
• Beneficiaries under an earlier will. An earlier document that gave the person more is a direct financial stake in setting aside the later one.
• Beneficiaries under the challenged will who did better in a prior version.

People with no financial stake do not get a hearing on the merits. A friend left out of every draft, a relative who would not inherit under intestacy, and a charity named in no version of the will are outside the class.

Inside the class, though, the bar sits low on purpose. A February 2026 Monmouth County Probate Part opinion, unpublished but instructive, let a descendant of a disinherited daughter go forward even though the daughter was the only person who would have inherited had the will fallen. She had died before the will was admitted to probate, and no one ever opened her estate. Because the plaintiff stood to inherit from her, he counted as aggrieved. Standing turns on the particular facts of a family, and it is one of the questions a New Jersey attorney assesses.

A separate remedy exists for a surviving spouse or partner who is unhappy with the split, and it is not a contest. The elective share under N.J.S.A. 3B:8-1 lets a surviving spouse, civil union partner, or domestic partner claim one-third of the augmented estate, and it carries its own rules, its own deadline, and its own disqualifiers, including a divorce complaint on file and a couple who had stopped living together under circumstances that would have supported a divorce. The New Jersey surviving spouse rights guide covers that claim. Which route fits a given family is a question for a licensed New Jersey attorney.

The Grounds New Jersey Recognizes

A will admitted to probate is treated as valid, and the person attacking it carries the burden. New Jersey courts start from the presumption that the testator was competent and of sound mind when the will was signed. That presumption comes from the New Jersey Supreme Court in Haynes v. First National State Bank of New Jersey, 87 N.J. 163 (1981), and the Appellate Division applied it again in April 2026 in an unpublished decision on a Camden County estate. Suspicion alone loses.

Lack of Testamentary Capacity

N.J.S.A. 3B:3-1 sets a low bar on paper: any individual 18 or more years of age who is of sound mind may make a will and may appoint a testamentary guardian. New Jersey courts measure sound mind by whether the testator could comprehend the property being disposed of, the natural objects of the testator's bounty, the meaning of the business being transacted, how those pieces relate to each other, and the distribution the will makes.

Capacity is judged at the moment of signing. A dementia diagnosis does not settle the question, because a person in cognitive decline can sign validly during a lucid stretch. Cases on this ground are won with medical records from the weeks around the signing, testimony from treating clinicians and caregivers, and accounts from people who watched the testator that month.

Undue Influence

Undue influence is the ground families reach for most and the one that turns on proof rather than instinct. New Jersey defines it as mental, moral, or physical exertion that has destroyed the free agency of a testator by preventing the testator from following the dictates of the testator's own mind and will, and accepting instead the domination and influence of another. Persuasion, suggestion, and even the possession of influence plus the chance to use it do not meet that standard.

The burden can shift. Where the will benefits someone who stood in a confidential relationship with the testator, and suspicious circumstances surround how the will came about, New Jersey puts the burden on the person who benefited to disprove undue influence by a preponderance of the evidence. That burden climbs to clear and convincing proof in sharper situations, including where the attorney who drafted the will is also a beneficiary.

The standard changes again when the fight is over a lifetime transfer rather than the will. For an inter vivos gift, a deed signed late in life, or a beneficiary designation added to a retirement account, New Jersey requires the person who received it to disprove undue influence by clear and convincing evidence, which is a stiffer test than the preponderance standard that governs a will. An unpublished June 2026 Monmouth County Probate Part opinion set both standards side by side, found a confidential relationship and suspicious circumstances, shifted the burden to the friend who had been named agent and beneficiary, and then ruled for him anyway after nine days of trial. Shifting the burden is not the same as winning.

Patterns that draw a court's attention include a caregiver or new companion who arrived shortly before the will changed, a testator cut off from family, a sharp break from a long-standing plan, and a beneficiary who picked the drafting attorney or sat in on the signing.

Fraud or Forgery

Fraud means the testator was deceived in a way that changed the document. It shows up two ways: fraud about what the paper was, such as telling someone a will was a power of attorney, and fraud about the facts behind a gift, such as a lie that a child had stolen from the parent. Forgery is a separate claim that the signature is not the testator's or the document was fabricated, and it usually needs a document examiner comparing the disputed signature against known samples.

New Jersey also carries a general anti-fraud provision that reaches beyond the will itself. N.J.S.A. 3B:1-9 lets anyone injured by fraud perpetrated in connection with a proceeding under Title 3B seek relief against the perpetrator, or restitution from someone who benefited, with a two-year limit running from discovery of the fraud and an outer limit of five years from the fraud for anyone who was not the perpetrator.

Improper Execution

N.J.S.A. 3B:3-2 sets the formalities a contest attacks. A will must be in writing, signed by the testator or in the testator's name by another individual in the testator's conscious presence and at the testator's direction, and signed by at least two individuals who each signed within a reasonable time after witnessing the signing or the testator's acknowledgment. Miss one and the document is open to challenge: only one witness signed, a witness never saw the signing or the acknowledgment, or the signature was made outside the testator's presence.

New Jersey softens the blow in two places, which is why a signing defect is not the automatic win it is in stricter states. N.J.S.A. 3B:3-2(b) validates a will that fails the witness rules if the signature and the material portions of the document are in the testator's handwriting. N.J.S.A. 3B:3-3 goes further and treats a defective document as a will where the proponent establishes by clear and convincing evidence that the decedent intended it as a will, a revocation, an alteration, or a revival. Both paths leave the Surrogate's office under Rule 4:82 and land in the Probate Part.

One evidence rule shapes how these cases are tried. N.J.S.A. 3B:3-23 requires the testimony of at least one attesting witness, if within the State and competent and able to testify, whenever execution is in issue in a contested probate action. Other proof of due execution is still admissible.

A Later Will or a Revocation

A will can also be attacked as no longer operative. N.J.S.A. 3B:3-13 revokes a will by a later will that revokes it expressly or by inconsistency, or by a revocatory act on the will itself, meaning burning, tearing, canceling, obliterating, or destroying it with intent to revoke, done by the testator or by someone else in the testator's conscious presence and at the testator's direction. The statute presumes a later will that disposes of the whole estate was meant to replace the earlier one, and that a partial later will only supplements it, with either presumption rebuttable by clear and convincing evidence.

Divorce does its own work. N.J.S.A. 3B:3-14 revokes dispositions, powers of appointment, and fiduciary nominations in favor of a former spouse and the former spouse's relatives, and severs joint tenancies and tenancies by the entirety into tenancies in common, unless the instrument, a court order, or a marital agreement says otherwise. Remarriage to the same person revives what the divorce revoked.

No-Contest Clauses Fail When You Have Probable Cause

Some wills carry an in terrorem clause that tries to strip the share of any beneficiary who challenges the document. New Jersey blunts it. N.J.S.A. 3B:3-47 says a provision in a will purporting to penalize any interested person for contesting the will or instituting other proceedings relating to the estate is unenforceable if probable cause exists for instituting proceedings.

Read that as a condition rather than a free pass. A beneficiary with real evidence of incapacity, undue influence, or a signing defect may file without automatically forfeiting a gift. A beneficiary proceeding on a hunch has no such cover. Whether a particular record clears probable cause is a legal judgment a licensed New Jersey attorney makes on the specific facts, and it can decide whether a bequest is kept or lost.

Contesting a Revocable Trust Runs on Different Deadlines

Plenty of New Jersey estates hold the real money in a revocable living trust, and the will is a short pour-over document. Attacking the trust is a separate action under the New Jersey Uniform Trust Code, with its own clock.

N.J.S.A. 3B:31-45 lets a person start a judicial proceeding to contest the validity of a trust that was revocable at the settlor's death within the earlier of three years after the settlor's death, or four months for a New Jersey resident and six months for a nonresident after the trustee sent that person a copy of the trust instrument along with notice of the trust's existence, the trustee's name and address, and the time allowed to sue. So a trustee who sends the notice can compress a three-year window to four months.

The standards travel with you. N.J.S.A. 3B:31-42 sets the capacity to create, amend, revoke, or add property to a revocable trust at the same level required to make a will, so a capacity theory that works against the will works against the trust. N.J.S.A. 3B:31-23 voids a trust to the extent its creation was induced by fraud, duress, or undue influence. Money already paid out is not gone: N.J.S.A. 3B:31-45 makes a beneficiary of a trust later held invalid liable to return any distribution received.

What a Contest Costs and What It Does to the Tax Clock

A New Jersey contest is litigation. Beyond the $175 first paper and the $110 answering paper, expect depositions of the drafting attorney and the attesting witnesses, subpoenas for medical and financial records, and expert reports on capacity or handwriting. Many cases settle at mediation because a negotiated split costs less than a trial and keeps the family in charge of the outcome.

The tax does not wait for the fight to end. New Jersey imposes no estate tax on the estate of a resident who died on or after January 1, 2018, but the Transfer Inheritance Tax survives, and the Division of Taxation requires the return and payment within eight months of the date of death, with interest at 10% a year on anything unpaid after that. R.S. 54:35-3 offers one break that fits this exact situation: where claims made upon the estate, necessary litigation, or another unavoidable cause of delay keeps the estate from being settled within eight months, only 6% a year is charged from the end of the eighth month until the cause of delay is removed. Proof of the pending litigation is what supports the lower rate.

The lien is the other reason a contest freezes everything. R.S. 54:35-5 makes the tax a lien on all property the decedent owned at death for 15 years, unless it is paid or secured by bond, which is why banks and title companies sit on assets while the case runs. Creditors keep their own schedule too: the nine-month bar under N.J.S.A. 3B:22-4 runs from the date of death no matter what the litigation does, as the New Jersey creditor claims guide explains.

What Happens If the Will Is Set Aside

Two outcomes are possible. If an earlier valid will exists, the estate follows that document, and the Surrogate or the court works from it instead. If no earlier will survives, the estate passes under New Jersey's intestate rules, which is often a very different split than the one that prompted the challenge.

That arithmetic often surprises families. A child who was cut to a small share sometimes takes less under intestacy than under the will, especially where a surviving spouse or partner takes the whole intestate estate under N.J.S.A. 3B:5-3. Comparing the will, any prior will, and the intestate result side by side is work a licensed New Jersey attorney does on the specific facts. The New Jersey executor duties guide covers what the personal representative still owes the estate while a dispute is open.

What a New Jersey Contest Is Assessed On

New Jersey contests turn on a short list of facts, and each one is easiest to establish early. The items below describe what the analysis generally rests on. They are not steps for any particular reader to take, and none of them is a substitute for a licensed New Jersey attorney's assessment of a specific matter.

1. The probate date in the Surrogate's record. That date, not the notice a beneficiary received in the mail, starts the four-month or six-month count under R. 4:85-1.
2. The Surrogate's file. The will, the proofs, the qualification papers, and the appointment date are public records in the county where probate was granted.
3. The calendar. R. 4:85-2 caps an extension at 30 days and conditions it on good cause and the absence of prejudice, so the practical working date sits well ahead of month four or six.
4. Medical records from the months around the signing, along with the drafting attorney and the attesting witnesses. Capacity is measured at the moment of signing, and N.J.S.A. 3B:3-23 brings at least one attesting witness into a case where execution is in issue.
5. Any in terrorem clause in the will. N.J.S.A. 3B:3-47 leaves it unenforceable where probable cause exists, so what a beneficiary stands to forfeit is part of the picture either way.
6. Where the assets actually sit. Property held in a revocable trust runs on the N.J.S.A. 3B:31-45 clock rather than R. 4:85-1.
7. Counsel, early. Standing, the available grounds, and the applicable deadline are all legal judgments made on the specific record, which is why a New Jersey probate litigator is the person who makes them.

Planning ahead is the cheaper side of this topic. For anyone worried that their own estate could end up here, the New Jersey will requirements guide covers the self-proved will that makes probate routine, and the avoid probate guide covers the transfers that keep assets out of the Surrogate's office entirely.

Common Questions

How long do I have to contest a will in New Jersey?

Four months after probate or the grant of letters if you live in New Jersey, and six months if you lived outside the State when probate was granted. Rule 4:85-1 sets both periods, and Rule 4:85-2 lets a judge add up to 30 more days on a showing of good cause and the absence of prejudice. A claim of fraud upon the court runs on a reasonable-time standard instead.

What is a caveat in New Jersey?

A caveat is a written objection filed with the County Surrogate before that office enters judgment admitting a will. Under Rule 4:82 the Surrogate's Court may not act in a matter where a caveat has been filed, so the case moves to the Superior Court, Chancery Division, Probate Part. Filing or withdrawing a caveat costs $25 under N.J.S.A. 22A:2-30.

What are the grounds to contest a will in New Jersey?

Lack of testamentary capacity, undue influence, fraud, forgery, a signing that did not meet N.J.S.A. 3B:3-2, and revocation by a later will or by a revocatory act under N.J.S.A. 3B:3-13. Being unhappy with your share is not a ground.

Who can contest a will in New Jersey?

Rule 4:85-1 lets any person aggrieved by the probate of a will or by the grant of letters file the complaint. That usually means an heir who would take under N.J.S.A. 3B:5-3 or 3B:5-4 if the will fell, a beneficiary named in an earlier will, or a beneficiary who would do better under an earlier document.

Does a no-contest clause work in New Jersey?

Not against a challenger with probable cause. N.J.S.A. 3B:3-47 makes a will provision that penalizes an interested person for contesting the will or starting other proceedings about the estate unenforceable if probable cause exists for starting those proceedings. Whether a particular record meets that standard is a question for a licensed New Jersey attorney.

Does a will contest pause the New Jersey Inheritance Tax?

No. The Division of Taxation still wants the return and the payment within eight months of the death, and interest runs at 10% a year after that. R.S. 54:35-3 does cut the rate to 6% for the stretch when necessary litigation or another unavoidable cause of delay keeps the estate from being settled.

This guide is general information about challenging a New Jersey will. A contest is litigation and the filing periods are short, so confirm the probate date, your standing, and your deadline with the County Surrogate or a licensed New Jersey attorney. It is not legal advice.

Sources:

• Title: New Jersey Court Rules, R. 4:82, Matters In Which The Surrogate's Court May Not Act. Publisher: New Jersey Courts. Publication Date: Rules of Court including amendments effective on or before June 1, 2026, accessed July 30, 2026. URL: https://www.njcourts.gov/attorneys/rules-of-court/482-matters-which-surrogates-court-may-not-act
• Title: New Jersey Court Rules, R. 4:84-1, the complaint and order to show cause any person in interest files where the Surrogate's Court may not act. Publisher: New Jersey Courts. Publication Date: Rules of Court including amendments effective on or before June 1, 2026, accessed July 30, 2026. URL: https://www.njcourts.gov/attorneys/rules-of-court?id=4%3A84-1&section=All
• Title: New Jersey Court Rules, R. 4:85-1, Complaint; Time for Filing (four months, or six months for a person residing outside the State). Publisher: New Jersey Courts. Publication Date: Rules of Court including amendments effective on or before June 1, 2026, accessed July 30, 2026. URL: https://www.njcourts.gov/attorneys/rules-of-court/complaint-time-filing
• Title: New Jersey Court Rules, R. 4:85-2, Enlargement of Time, and R. 4:85-3, After-Discovered Will. Publisher: New Jersey Courts. Publication Date: Rules of Court including amendments effective on or before June 1, 2026, accessed July 30, 2026. URL: https://www.njcourts.gov/attorneys/rules-of-court?id=4%3A85-2&section=All
• Title: New Jersey Court Rules, R. 4:80-6, Notice of Probate of Will. Publisher: New Jersey Courts. Publication Date: Rules of Court including amendments effective on or before June 1, 2026, accessed July 30, 2026. URL: https://www.njcourts.gov/attorneys/rules-of-court?id=4%3A80-6&section=All
• Title: N.J.S.A. 3B:3-1, 3B:3-2, and 3B:3-3, capacity to make a will, execution of witnessed wills, and writings intended as wills. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: N.J.S.A. 3B:3-13, 3B:3-14, 3B:3-22, 3B:3-23, and 3B:3-47, revocation, revocation by divorce, the 10-day wait before probate, proof of execution in a contested probate action, and the penalty clause for contesting a will. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: N.J.S.A. 3B:1-9, 3B:5-3, 3B:5-4, 3B:8-1, and 3B:22-4, effect of fraud and evasion, the intestate shares, the one-third elective share of the augmented estate, and the nine-month limit on creditor claims. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: N.J.S.A. 3B:31-23, 3B:31-42, and 3B:31-45, New Jersey Uniform Trust Code provisions on trusts induced by fraud, duress, or undue influence, capacity of the settlor of a revocable trust, and the limitation on an action contesting a revocable trust. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: N.J.S.A. 22A:2-30, fees of the surrogate and deputy clerk of the Superior Court, including the $25 caveat fee, the $175 first paper, and the $110 first answering paper in the Chancery Division, Probate Part. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: R.S. 54:35-1, 54:35-3, and 54:35-5, Transfer Inheritance Tax due date, interest on delayed payment including the 6% rate during necessary litigation, and the 15-year lien. Publisher: New Jersey Legislature, Office of Legislative Services. Publication Date: New Jersey General and Permanent Statutes, updated through P.L.2025, c.346, and J.R.22, accessed July 30, 2026. URL: https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1?f=templates&fn=default.htm&vid=Publish:10.1048/Enu
• Title: Inheritance Tax Filing Requirements. Publisher: New Jersey Department of the Treasury, Division of Taxation. Publication Date: Not listed, accessed July 30, 2026. URL: https://www.nj.gov/treasury/taxation/inheritance-estate/inheritance-taxfilerequirements.shtml
• Title: Lien on and Transfer of a Decedent's Property: Tax Waiver Requirements. Publisher: New Jersey Department of the Treasury, Division of Taxation. Publication Date: Not listed, accessed July 30, 2026. URL: https://www.nj.gov/treasury/taxation/inheritance-estate/estatetax.shtml
• Title: In the Matter of the Estate of Veronica E. Carter, Docket No. A-2767-24, unpublished per R. 1:36-3, restating the presumption of testamentary capacity from Haynes v. First National State Bank of New Jersey and the Rule 4:85-1 standard. Publisher: New Jersey Courts, Appellate Division. Publication Date: Decided April 28, 2026. URL: https://www.njcourts.gov/system/files/court-opinions/2026/a2767-24.pdf
• Title: In the Matter of the Estate of Lois Foster, Docket No. MON-P-422-24, unpublished, on the low bar for standing to contest a will under Rule 4:85-1. Publisher: New Jersey Courts, Chancery Division, Probate Part, Monmouth County. Publication Date: Decided February 27, 2026. URL: https://www.njcourts.gov/system/files/court-opinions/2026/mon-p-422-24.pdf
• Title: In the Matter of Motoko Hayashi, Docket No. MON-P-435-24, unpublished, applying the confidential relationship and suspicious circumstances test that shifts the burden on undue influence and the clear and convincing standard for inter vivos transfers. Publisher: New Jersey Courts, Chancery Division, Probate Part, Monmouth County. Publication Date: Decided June 30, 2026. URL: https://www.njcourts.gov/system/files/court-opinions/2026/imo_hayashi.pdf

It is not legal advice.