Undue influence disputes[1] often involve no allegations of overt fraud, coercion, or incapacity, instead turning on the fairness of transactions that occur within confidential relationships. A recent Mississippi Court of Appeals’ decision[2] provides a clear illustration of how courts analyze these disputes and why the burden imposed on a beneficiary who occupies a position of trust is intentionally high.
In Lucas, the Court of Appeals affirmed the Pearl River County Chancery Court’s decision setting aside a quitclaim deed executed by an elderly mother in favor of her son who had moved into her home and assumed the role of caregiver. Although the son did not dispute that a confidential relationship existed or that a presumption of undue influence applied, he argued that the evidence was sufficient to rebut that presumption. The appellate court disagreed, emphasizing both the heightened scrutiny of the rebuttal standard and the limited scope of appellate review in such cases.
Factual Background and the Transfer at Issue
Decedent and her late husband had six children. After her husband’s death in 2015, Decedent executed a will directing that her residence be sold and the proceeds divided into equal shares among her children and grandchildren. At the time the will was prepared, Decedent was living independently and managing her affairs without assistance.
Over the ensuing years, Decedent’s physical health declined. She experienced heart-related medical issues and suffered a disorienting driving incident that led her to stop driving altogether. As her dependence increased, her son Jason moved into the home to assist her with transportation, medical appointments, shopping, and household needs. In 2017, Decedent executed a durable power of attorney naming Jason as her agent and added him as a joint owner on her bank accounts.
Two years later, in 2019, Decedent executed a quitclaim deed transferring ownership of her home to Jason, an act that directly contradicted the distribution scheme set forth in her will. Jason later sold his own home, showing his reliance on the transferred property. For a time, the transfer went largely unchallenged, though at least one sibling learned of it and expressed concern, albeit without bringing formal action.
By 2022, Decedent’s relationship with Jason had deteriorated. She contacted another son, Harry, expressing fears that Jason was interfering with her communications and finances. With assistance from Harry and her daughter Amy, Decedent revoked Jason’s power of attorney. Shortly thereafter, Decedent initiated litigation seeking to set aside the quitclaim deed on the grounds of undue influence. Decedent passed away before the case was tried, and the action proceeded through her estate.
The Chancery Court’s Undue Influence Analysis
The chancery court appropriately began by determining whether a confidential relationship existed between Decedent and Jason at the time of the transfer. The court found that all relevant factors in determining the existence of a confidential relationship, raising a presumption of undue influence, were not only present but undisputed. Jason was Decedent’s son, lived with her, provided daily care, controlled transportation, held a power of attorney, shared joint bank accounts with her, and assisted her while she was physically weak and in declining health. These facts, along with Jason’s concession to this point, were more than sufficient to establish a confidential relationship under Mississippi law.
Once a confidential relationship was established, a presumption of undue influence arose with respect to the quitclaim deed. At that point, the burden shifted to Jason to rebut the presumption by clear and convincing evidence. The chancery court acknowledged that Decedent appeared mentally sharp during the relevant period, a fact that weighed in Jason’s favor. However, mental capacity alone does not defeat a claim of undue influence when a confidential relationship exists.
Critically, the chancery court found that Jason failed to produce sufficient evidence to meet the heightened rebuttal standard. He presented no disinterested witnesses and relied primarily on his own testimony to establish the fairness and voluntariness of the transaction. The court concluded that this proof was inadequate and set aside the deed.
The Appellate Standard and the Rebuttal Burden
On appeal, Jason did not contest the existence of the confidential relationship or the presumption of undue influence. Instead, he argued that the chancery court erred in finding that he failed to rebut the presumption. This position significantly narrowed the appellate inquiry.
The Court of Appeals emphasized the highly deferential standard governing review of chancery court findings. A chancellor’s factual determinations will not be disturbed when supported by substantial evidence unless they are manifestly wrong or clearly erroneous.[3] This standard is especially consequential in undue influence cases, where credibility determinations and fact-intensive evaluations are central.
The appellate court also underscored the demanding nature of the rebuttal burden. Once a confidential relationship is established, the grantee must overcome the presumption of undue influence by clear and convincing evidence.[4] This standard exceeds even the “overwhelming weight of the evidence” threshold and places a substantial evidentiary burden on the beneficiary seeking to uphold the transaction.[5] As the Court noted, a party facing such a burden at trial necessarily confronts an even steeper challenge on appeal.[6]
Why Beneficiary’s Evidence Fell Short
Jason’s primary contention was that Decedent possessed the mental capacity to convey the home and that the transfer was not concealed from the family. He also emphasized that some consideration, a nominal ten dollars, was paid for the property and that his siblings did not immediately challenge the transaction.
The Court of Appeals rejected these arguments. First, it reiterated that appellate courts do not reweigh evidence or substitute their judgment for that of the chancellor. Second, and more fundamentally, Mississippi precedent makes clear that the testimony of the interested party alone is insufficient to rebut a presumption of undue influence.[7] Where the only witnesses are the alleged influencer and the interested challengers, the absence of any disinterested testimony is fatal to the defense.
The Court’s analysis reflects a consistent theme with respect to undue influence under Mississippi law: there is no presumption of wrongdoing, but rather a presumption of invalidity, when a transaction occurs within a confidential relationship, and such presumption can be overcome only be an affirmative demonstration of fairness. That presumption exists not to punish caregivers, but to protect vulnerable individuals and to ensure that courts can be confident in the integrity of inter vivos transfers and/or testamentary transfers made under conditions of dependency.
The Protective Function of the Presumption
In affirming the chancery court, the Court of Appeals reiterated the broader policy considerations underlying undue influence doctrine. Mississippi courts have long recognized a “solemn duty” to prevent dominant parties in confidential relationships from exploiting those who depend on them.[8] When a conveyance of dubious consideration flows from the dependent party to the dominant party, the law presumes the transaction void not because it is certainly unfair, but because the court cannot be certain that it is fair.[9]
In Lucas, Jason offered no evidence beyond his own assurances that the transaction was free of undue influence. Under longstanding precedent, that showing was insufficient as a matter of law. The chancery court’s decision to set aside the deed was therefore not only supported by the record, but consistent with the protective principles of undue influence under Mississippi law.
Conclusion
This case reinforces a central lesson for estate planners, fiduciaries, and family caregivers alike. To survive an undue influence challenge to property transfers that occur within a confidential relationship, the beneficiary of such a transfer must be prepared to demonstrate through clear, convincing, and independent evidence that the transaction was fair, voluntary, and free from undue influence.[10] When undertaking any transfers that may later be challenged, independent advice, disinterested witnesses, and consistency with existing estate plans are often decisive factors in determining whether a transfer will withstand judicial scrutiny. In their absence, even well-intentioned transactions are vulnerable to being undone. Ultimately, Lucas reflects the high burden imposed on beneficiaries in confidential relationships, a deliberate safeguard that courts will continue to enforce when caregivers receive substantial gifts.
[1] See prior articles regarding undue influence cases here: https://www.esapllc.com/will-disputes-fleishhacker-2025/; https://esapllc.com/sojourner-ms-case-undue-influence-2025/; https://esapllc.com/undue-influence-lessons-from-the-estate-of-effie-mae-autry-2025/
[2] Lucas v. Estate of Lucas by & through Reyna, No. 2024-CA-01259-COA, 2025 WL 3638214 (Miss. Ct. App. Dec. 16, 2025).
[3] Weirich v. Murchison, 200 So. 3d 1085, 1089 (Miss. Ct. App. 2016).
[4] Id. at 1090.
[5] Miss. Comm’n on Jud. Performance v. Shoemake, 191 So. 3d 1211, 1218 (Miss. 2016).
[6] Mullins v. Ratcliff, 515 So. 2d 1183, 1189 (Miss. 1987); Matthews v. Whitney Bank, 282 So. 3d 786, 794 (Miss. Ct. App. 2019).
[7] In re Estate of Holmes, 961 So. 2d 674, 681 (¶19) (Miss. 2007); In re Estate of Autry, 407 So. 3d 200, 205 (Miss. 2025).
[8] Estate of McRae, 522 So. 2d 731, 740 (Miss. 1988).
[9] Id. at 737.
[10] See my prior article, where the presumption of undue influence was overcome: https://esapllc.com/sojourner-ms-case-undue-influence-2025/
