In 1999, Edison Milbourne suffered a work-related brain injury that impaired his ability to care for himself independently. He initially lived at home with his wife, Janita, and his infant child, Janay, but was later moved to different rehabilitation facilities. Edison’s sister, Vashti, was appointed as guardian in 2009, one month after a \($726,000\) workers’ compensation settlement was finalized. Vashti moved Edison out of his rehabilitation facility and began making significant financial demands allegedly to cover her costs as Edison’s caregiver. These demands allegedly included a Cadillac Escalade, \($300,000\) for a home, \($27,000\) to furnish the home, and a \($30,000\) advance for future services to be rendered. Edison executed a will in January 2013, the arrangements for which were largely made by Vashti. Nine months later, in October 2013, Edison executed a new will. Edison died in July 2014, and Vashti submitted the October will to probate. Janay objected to this filing and alleged that the October will was procured through undue influence. A jury returned a verdict denying probate of the October will, concluding that it was invalid because Vashti had exercised undue influence and because Edison had failed to properly execute the document.

Vashti and her daughter then submitted the January will for probate. Janay objected and alleged that lack of testamentary capacity, fraud, undue influence, and revocation barred probate. Janay also contended Edison explicitly told Vashti that he no longer wanted the January will, and Vashti breached the fiduciary duty that she owed to Edison as his legal guardian by failing to destroy the document. The probate court denied Janay’s claim that Edison’s actions constituted an effective revocation of the January will, and Janay appealed. Was Edison’s alleged oral declaration sufficient to revoke the January will? What acts may constitute destruction of a will sufficient to constitute revocation?