Electronic wills in Missouri: The future is now

John M. Challis[1]

For the past 60 years, Missouri lawyers have learned the same statutory requirements for the creation of a valid last will and testament in Missouri: (1) it must be in writing; (2) it must be signed by the testator or someone at her direction and in her presence; and (3) it must be witnessed by two or more competent witnesses in the presence of the testator.[2]

But in reality, the requirements for the valid creation of a will have been around much longer. Missouri draws its Statute of Wills from the English Statute of Frauds of 1677,[3] and these requirements were also included in Missouri’s territorial laws prior to statehood.[4] These basic elements have remained largely unchanged for the past 450 years.

In the age of the smartphone, social media, and cloud storage, should these requirements evolve? Further, given the number of will substitutes available with less onerous execution requirements (including trusts and pre-death and on-death transfers), wills are of decreasing importance. Technological advances are nothing new, and in many ways Missouri laws have stayed current.[5] Restraint is justified to avoid fads, but the question remains whether it is time to reconsider the inviolate requirements of will preparation, execution, and probate.

The Missouri Bar recently created a subcommittee on electronic wills to consider just this issue. Missouri will not be the first state to consider permitting some form of electronic will, and it likely will not be the last. Given that there are already multiple states that permit electronic wills, the reality is that Missouri practitioners and courts will have to deal with some aspects of electronic wills – including the probate thereof.[6]

“Electronic Wills” Are Already Here

Assume you have recently been hospitalized and are told that you have only days to live.[7] You do not have much in the way of assets, but you do want to ensure that the right people receive your limited assets upon death. You have no paper and no pen, but you do have the iPad you have used to watch Netflix the past couple of weeks in the hospital. Your family and friends are at your side and you tell them that you want to make a will. You tell your sister what you want to say, and she dutifully writes everything down on the iPad with a stylus. She reads it back to you to make sure it is exactly correct. It is short – all it says is that upon your death, you want your house to go to your friend, your car to your brother, and your treasured baseball card collection to your nephew. You sign the iPad using the stylus, and so do your parents. Your mother retains the password-protected iPad until your death two days later and thereafter. A month later, your mother arrives at the probate court and asks for the forms to admit your will and open probate. Should your “iPad will” be admitted? Although the issue has never been presented in Missouri, the answer appears to be “yes.”

Present Missouri law requires that all wills be “in writing.”[8] Nowhere in Chapter 474 is “in writing” defined, but elsewhere in Missouri law, applicable to “the statutory laws of this state,” that phrase is interpreted to include “printing, lithographing, or other mode of representing words and letters.”[9] Missouri courts have consistently held that “[a]nything written, in any form, goes for a will, if it reveals the intention of the maker to dispose of his property at death.”[10] So, your iPad may well be “in writing” under Missouri law.

Missouri law also requires that the will be “signed by the testator, or by some person, by his direction, in his presence.”[11] Again, that requirement is not further discussed in Chapter 474, but it is elsewhere stated that “in all cases where the signature of any person is required, the proper handwriting of the person, or his mark, is intended.”[12] Given that you signed the iPad with the stylus, it appears that you properly “signed” your will. Indeed, had your sister signed your name or made your mark at your direction, this would have been sufficient – even if you had the ability to sign it yourself.

Finally, your will must be “attested by two or more competent witnesses subscribing their names to the will in the presence of the testator.”[13] The testator is required to “publish” her will to the witnesses – that is, she must “either by words, acts, signs or conduct make it clear to the witnesses that he intends the paper signed to be his will….”[14] There are additional considerations for will witnesses. Although a will is not invalid because a witness receives something thereunder, if there are not two or more disinterested witnesses, interested witnesses must “forfeit so much of the provisions therein made for him as in the aggregate exceeds in value, as of the date of the testator’s death, what he would have received had the testator died intestate.”[15] Because your parents, who receive nothing under this iPad will, were the witnesses, it was properly witnessed.

Based on the foregoing, it appears your iPad will may well be valid and should be probated in the State of Missouri. While there may be additional difficulties in the probate process given the lack of compliance with the self-proving will statute,[16] the unique form and presentation of this document should not destroy your donative intent. This was exactly the situation in the Ohio case of In re: Estate of: Javier Castro, Deceased (“Castro”).[17] In Castro, the probate court for Lorain County, Ohio, probated a will prepared and signed on a tablet.[18] It determined that the requirements for a valid Ohio will (which are similar to those in Missouri) were satisfied by the tablet, which was signed by the testator and two witnesses.[19] The Castro court then opened probate for the decedent to be administered in accordance with the tablet will.[20]

While these types of “offline” electronic wills have been exceedingly rare in the law, their frequency will increase with time.[21] Both to address these scenarios,[22] as well as more fully electronic wills, a number of states and the Uniform Law Commission (“ULC”) have considered, and are considering, electronic will legislation.

The Genesis of Electronic Wills

In 2000, Congress passed the Electronic Signatures in Global and National Commerce Act,[23] which allowed for electronic signatures in “any transaction in or affecting interstate or foreign commerce.”[24] But like Missouri’s adoption of the Uniform Electronic Transactions Act,[25] that statute specifically excepted any “statute, regulation, or other rule of law governing the creation and execution of wills, codicils, or testamentary trusts.”[26] Consequently, current law was of no assistance to those seeking to execute an electronic will.

One year later, however, the Nevada Legislature passed Senate Bill 33, which was signed into law by Gov. Kenny Guinn on June 6, 2001.[27] What could have been a revolutionary change in probate law, however, never really came about. The 2001 Nevada statute provided that electronic wills were valid so long as they (1) are written, created, and stored in an electronic record; (2) contained the date and the electronic signature of the testator and which includes, without limitation, at least one authentication characteristic of the testator; and (3) created and maintained such that (i) only one authoritative copy exists; (ii) that copy is maintained by the testator or custodian; and (iii) authoritative copies are readily identifiable as such.[28] The requirement for an “authentication characteristic” included things such as a “fingerprint, a retinal scan, voice recognition, facial recognition, [or] a digitized signature.”[29] These requirements were seen as onerous, especially in a state that allows for holographic wills.[30] As a result, Nevada electronic wills under the 2001 statute never gained wide popularity.

The Recent Push for Electronic Wills

Over the past several years, there have been renewed discussions regarding electronic wills. Companies that seek to offer online electronic will services have advocated for an overhaul of states’ probate codes to allow for those documents.[31] Three states have joined Nevada in allowing electronic wills, and the ULC recently passed a model act.[32]

Nevada revised its electronic will statute in 2017.[33] The state expanded on the provisions allowing for a valid electronic will by adding notarial certification and dual witnessing as alternatives to the existing “authentication characteristic.”[34] But Nevada went a step further. There, required notarial certification and/or witnessing can be performed remotely. While the notary and/or witnesses must be in the “presence” of the testator, presence includes “[d]ifferent physical locations but can communicate with each other by means of audio-video communication.”[35] Further, the Nevada statute provides that a will can be validly executed under Nevada law even outside the State of Nevada so long as (1) the document states that Nevada law applies; (2) the witnesses or notary are in Nevada; or (3) the testator understands and intends to make a Nevada will.[36] The net result of this is that a Missouri testator, from the comfort of his or her couch, can make a legally binding Nevada electronic will without ever leaving the state. And when that testator dies, Missouri courts will be left to struggle with whether and how to probate that will.

Similar legislation was proposed in Florida and passed by the legislature in 2017,[37] but was ultimately vetoed by Gov. Rick Scott.[38] In his veto letter, Scott raised concerns regarding the electronic notary and other provisions, including remote witnessing.[39] Scott recommended that the legislature “address the issues comprehensively during the next legislative session.”[40] In 2019, the Florida Legislature passed, and Gov. Ron DeSantis signed, House Bill 409 that will go into effect January 1, 2020.[41] Similar to the prior proposed legislation, this new law will permit remote witnessing and notarization.[42] Importantly, however, Florida will not permit “vulnerable adults”[43] to have documents recorded in electronic format, remotely notarized, or remotely witnessed.[44]

In 2018, the Indiana Legislature passed, and Gov. Eric Holcomb signed, House Bill 1303, which permitted for the first time electronic wills in Indiana.[45] That bill added a new Chapter 21 to the Indiana Probate Code. The Indiana electronic will law does not allow for remote notarization or remote witnessing.[46] It provides for significant regulations that must be followed, including directions to the testator, maintenance of the electronic will, filing of the electronic will, and revocation of the electronic will.[47] Indiana further states that electronic wills are only valid if they were validly executed (1) in Indiana; (2) in the state where the testator was physically present at execution; or (3) where the testator died.[48]

Arizona has also passed electronic will legislation that went into effect July 1, 2019.[49] Similar to Indiana, Arizona also requires the physical presence of the testator, witness, and notary public.[50] To be self-proving, the electronic will must also designate a custodian who is neither related to the testator nor a recipient of any bequest under the electronic will.[51] That qualified custodian must also maintain a photograph of the testator and the witnesses, a video and audio recording of the execution, and copies of all parties’ relevant identification.[52] Similar to Indiana, that bill also contains other procedural mechanisms and safeguards.[53]

Other states and territories, including New Hampshire, Virginia, California, and the District of Columbia have either introduced or considered legislation relating to electronic wills. To date, none of these has become law.

The ULC Process

The ULC (formerly known as the National Conference of Commissioners on Uniform State Laws), “established in 1892, provides states with non-partisan, well-conceived and well-drafted legislation that brings clarity and stability to critical areas of state statutory law.”[54] Missouri has adopted, either in whole or in part, dozens of uniform state laws. In the probate and trust context, this includes the Uniform Trust Code, the Uniform Fiduciary Access to Digital Assets Act, the Uniform Simultaneous Death Act, the Uniform Transfers to Minors Act, and others. Often, Missouri practitioners will be involved either directly with the drafting of, or input into, the proposed uniform law.

In October 2017, the ULC Committee on Electronic Wills began working on drafting a model statute. In considering legislation, the committee considered 10 key issues:

1. What is an electronic will?

2. What definitions will be needed?

3. How is an electronic will created?

4. How should an electronic will be signed?

5. How will an electronic will be stored?

6. What is the effect of a codicil?

7. How is an electronic will revoked?

8. Will an electronic will executed in one state be valid in another?

9. Should there be a supervisory entity for service providers?

10. What are potential costs and fiscal notes?[55]

In March 2018, this committee produced its first draft of a model electronic wills act.[56] That draft legislation attempted to answer certain of the aforementioned questions, but in a way that would allow states maximum flexibility given varying probate laws. That committee continued its work and ultimately approved and recommended for enactment in all states the Uniform Electronic Wills Act during its July 2019 annual conference.[57]

Caution is Justified

A balance must be achieved between recognizing the traditional functions of a will or other testamentary document and the benefits of evolving technology. It has been stated (and recognized by ULC)[58] that a will traditionally serves four functions:

1. The evidentiary function: One of the primary purposes of a will is to provide the court and the beneficiaries with evidence of the testator’s intent and wishes;

2. The channeling function: Wills force testators to formally set forth their wishes in a somewhat standardized format;

3. The cautionary function: By maintaining a seriousness to formal will execution and probate, the testator’s true and final intentions are realized; and

4. The protective function: The heightened requirements of will execution tend to discourage improper influence, as well as forgeries and perjury.

With these goals in mind, the question is whether these same functions can be achieved in a time of ever-evolving technology. Missouri may avoid “will by text message” or “will by Twitter,” but there are certainly options that can be considered to modernize Missouri’s requirements to incorporate technology while maintaining the safeguards and functions identified above. In so doing, one temptation to be avoided is to look at electronic wills only in terms of today’s technology. What would have happened if Missouri passed “will-by-fax” legislation in the 1980s or 1990s?

Regardless of whether statutory modification is ultimately adopted, it should at least be considered. As stated above, these issues may already arise, such as the Castro tablet will. And given the fact that other states now permit electronic wills, Missouri will need to address how to probate them. Statutory modification will prevent the likely haphazard results that would come with 115 probate courts independently considering tablet and foreign electronic wills, and, if completed correctly, will similarly avoid the need to wait for appellate guidance on what could be, by that time, outdated technology.

Even though some states have already enacted electronic will legislation, and others undoubtedly will, there is no need to rush into comprehensive electronic will legislation. Much will be learned from the experiences of the ULC and the other states that are considering this issue. More ideas will emerge, and Missouri can be guided by reviewing many different options for potential implementation. The likelihood of harm is much greater with rushed legislation than with addressing a small number of fact-specific probate inquiries. The ULC has stated that the goals of a statute on electronic wills should include:

1. To allow a testator to execute a will electronically, while maintaining the safeguards wills law provides for wills executed on something tangible (usually paper);

2. To create execution requirements that, if followed, will result in a valid will without a court hearing to determine validity, if no one contests the will; and

3. To develop a process that would not enshrine a particular business model in the statutes.[59]

These goals are worthy of consideration. Missouri occupies an odd position when it comes to probate and trust laws. In some areas, it is a leader and one of the first to adopt legislation. But in others, it is less willing to consider changes adopted in other states. By way of example, Missouri still does not allow holographic wills (unless the formalities of Missouri’s Statute of Wills are met); nor does it allow for even harmless errors in the execution of wills. One thing for which Missouri is well known, however, is the careful and deliberate consideration of changes to its probate and trust laws. Electronic wills should be no different.

Items to Consider

In moving forward in this process, there are a number of things to consider. These are not dissimilar to the questions that the ULC has identified above, but Missouri has a few unique issues. Missouri still operates largely on its own probate code that was adopted in the 1950s. Missouri did not adopt the totality of the Uniform Probate Code, on which aspects of the ULC model legislation is based. As a result, Missouri will need to review its probate statutes to determine which provisions would need to change to allow for electronic wills.

Assuming the threshold question of whether Missouri wants to consider electronic wills is answered in the affirmative, the next issue will be in what form and how far Missouri will go. There are ways to draft electronic will legislation that looks much more like a traditional will execution as opposed to “will by text.” Many believe the functions listed above and the safeguards in the current Statute of Wills can be maintained yet updated. Others are likely to say that the current system works just fine. But the reality is the majority of the members of Generation X and later do not have estate plans. Specific issues to consider would include the following:

1. Should Missouri require the witnesses and the notary to be in the same physical location as the testator, or should it embrace the concept of “electronic presence”?

2. Should Missouri consider changes to the notary public laws to allow for remote online notarization irrespective of the electronic wills issue?

3. Should Missouri require that the electronic will be in a written medium, or should it consider audio or video wills?

4. How should Missouri handle the revocation of electronic wills where many electronic copies may exist?

5. Should Missouri consider utilizing custodians for these documents?

6. Should Missouri create a procedure for creating a paper copy of the electronic document to be probated?

7. Should Missouri consider a “harmless error” statute for written or electronic wills such that documents not in conformity with the statutory requirements could still be admitted based on a showing of clear and convincing evidence?

Even assuming Missouri does not wish to enact comprehensive electronic wills legislation, it must still address whether to admit to probate electronic wills from other states. Currently, Missouri courts will probate a will if it is validly executed “where the will is executed.”[60] Given that states such as Nevada and Florida will deem electronic wills executed in those states even when done so remotely (including from Missouri), that statute should be addressed regardless.[61]

Missouri must also decide whether this discussion should include trusts as well as wills.[62] Our state law already recognizes that trusts have lower execution requirements than wills. Missouri trusts are not even required to be in writing (unless they transfer an interest in land).[63] It would therefore make sense – if changes are considered to the requirements for the execution of a will to allow for electronic wills – that clarifications are also considered on electronic trusts and potentially other electronic estate planning documents as well.

Conclusion

“[I]n this world nothing can be said to be certain, except death and taxes.”[64] Missouri law has, for longer than its statehood, recognized that its citizens are free to dispose of their property by will. Now, centuries later, there are available technologies that could make it easier than ever for Missourians to express their donative intent. But as with all technology, these changes come with consequences and potential dangers. Missouri should consider if, and how, to allow for the drafting, execution, and probate of electronic wills.[65]

Endnotes

1 John M. Challis is the chairperson of The Missouri Bar Subcommittee on Electronic Wills and chairperson of The Missouri Bar Fiduciary Litigation Committee. He is a partner in the St. Louis office of Kirkland Woods & Martinsen, LLP. Challis is a frequent speaker on topics related to probate and trust administration and litigation throughout Missouri. He can be reached at (314) 944-5201 or jchallis@kwm-law.com.

2 Section 474.320, RSMo 2017. A narrow exception applies for noncupative (oral) wills made by persons in “imminent peril of death” that are limited to $500 in property. Section 474.340, RSMo 2017.

3 29 Car 2 c 3.

4 Act July 4, 1807, 1 Terr. L., p. 131, § 18.

5 By way of example, in 2003 Missouri adopted the Uniform Electronic Transactions Act. Section 432.200, RSMo 2017, et seq. This act provides, in part, that “[a] record or signature shall not be denied legal effect or enforceability solely because it is in electronic form.” Section 432.230, RSMo 2017. Anyone who has used DocuSign or similar services is familiar with these types of documents. But this act specifically does not apply to the “creation and execution of wills, codicils, or testamentary trusts.” Section 432.210.2, RSMo 2017.

6 Section 474.360, RSMo 2017, provides that a will is valid and may be probated in this state if it is “executed in compliance with: . . . (2) The laws, as of the time of execution, of the place where the will is executed.” As a result, if an electronic will is validly created in any state that permits such documents, it can be admitted to probate in Missouri.

7 Further assume that you are at least 18 years of age and of sound mind, such that you are capable of making a will. Section 474.310, RSMo 2017.

8 Section 474.320, RSMo 2017.

9 Section 1.020(22), RSMo 2017.

10 Adams v. Simpson, 213 S.W.2d 908, 913 (Mo. 1948).

11 Section 474.320, RSMo 2017.

12 Section 1.020(22), RSMo 2017.

13 Section 474.320, RSMo 2017. It should be noted that although most wills prepared by practitioners contain “attestation clauses” that will recite the matters witnessed – specifically the capacity of the testator, the request of the testator to witness the document, and the presence with the testator – such clauses are not required in Missouri to create a valid will. Burkland v. Starry, 234 S.W.2d 608, 611 (Mo. 1950).

14 Hodges v. Hodges, 692 S.W.2d 361, 369 (Mo. App. S.D. 1985).

15 Section 474.330, RSMo 2017.

16 Section 474.337, RSMo 2017 provides that a will may be self-proving (and thus eliminating the need for the witnesses to testify as to its admission) if the statutory form is followed, including the presence of a notary public. While self-proving wills are advisable and easier to admit to probate, a non-self-proving will may still be admitted to probate upon proof in solemn form.

17 No. 2013ES00140 (Lorain Co. Ct. of Common Pleas, Jun. 19, 2013), available at 27 Quinnipiac Prob. L.J. 412 (2014).

18 Id. at 414.

19 Id. at 416-17.

20 Id. at 418.

21 The lack of legislation also leaves open questions, including whether a /s/ or other electronic signature would suffice in Missouri. A court in Tennessee has already held that it is sufficient under that state’s law. Taylor v. Holt, 134 S.W.3d 830, 831 (Tn. Ct. App. 2003).

22 While these facts lead to the likely conclusion that the “tablet will” is admissible to probate, one could imagine slight changes to this scenario that would make the question of the admissibility a much more difficult question. For example, the Michigan Court of Appeals admitted an unsigned electronic note on the decedent’s phone under the Michigan “harmless error” statute. Estate of Horton, 925 N.W.2d 207 (Mich. Ct. App. 2018). These types of “harmless error” statutes permit the admission of a will that does not comply with the statutory requirements. Only 11 states have such statutes, and Missouri is not one of them.

23 114 Stat. 464 (2000).

24 15 U.S.C. § 7001.

25 Section 432.210.2, RSMo 2017.

26 15 U.S.C. § 7003(a)(1).

27 Nev. S.B. 33, 71st Session (2001).

28 Nev. Rev. Stat. § 133.085 (2001).

29 Id.

30 Holographic wills are those which are written and signed by the testator, but otherwise not witnessed or executed with the normal formalities of a will. See Nev. Rev. Stat. § 133.090 (2001). Missouri does not permit holographic wills to be validly executed Missouri wills, but will probate holographic wills validly executed in other states. Section 474.360, RSMo 2017; see also 5 Mo. Prac., Probate Law & Practice § 254.

31 Willing.com, Modernizing The Law To Enable Electronic Wills, available at https://willing.com/learn/modernizing-the-law-to-enable-electronic-wills.html (last visited Oct. 5, 2019).

32 Information related to the ULC’s efforts on electronic wills is available at https://www.uniformlaws.org/committees/community-home?CommunityKey=a0a16f19-97a8-4f86-afc1-b1c0e051fc71 (last visited Oct. 5, 2019).

33 Nev. A.B. 413, 79th Session (2017).

34 Nev. Rev. Stat. § 133.085 (2017).

35 Nev. Rev. Stat. § 133.088 (1)(a)(2) (2017).

36 Nev. Rev. Stat. § 133.088(1)(e ) (2017).

37 Fla. Comm. Sub, H.B. 277, 2017 Session (2017).

38 Letter from Gov. Rick Scott to Secretary of State Ken Detzner (June 26, 2017), https://www.flgov.com/wp-content/uploads/2017/06/HB-277-Veto-Letter.pdf (last visited Oct. 5, 2019).

39 Id.

40 Id.

41 Fla. Comm. Sub, H.B. 409, 2019 Session (2019).

42 House of Representatives Staff Analysis of Fla. Comm. Sub, H.B. 409, 2019 Session (2019) available at https://www.flprobatelitigation.com/wp-content/uploads/sites/206/2019/09/h0409z1.CJS_-1.pdf (last visited Oct. 5, 2019).

43 “‘Vulnerable adult’ means a person 18 years of age or older whose ability to perform the normal activities of daily living or to provide for his or her own care or protection is impaired due to a mental, emotional, sensory, long-term physical, or developmental disability or dysfunction, or brain damage, or the infirmities of aging.” Fla. Stat. Ann. § 415.102(28) (2019).

44 Fla. Comm. Sub, H.B. 409, 2019 Session (2019).

45 Ind. H.B. 1303, 2018 Session (2018).

46 Ind. Code § 29-1-21-3(1) (2018); Ind. Code § 29-1-21-4 (2018).

47 Ind. Code § § 29-1-21-6 - 29-1-21-18 (2018).

48 Ind. Code § 29-1-21-7 (2018). This would appear to avoid the issue of Nevada or other wills remotely executed from Indiana being probated in Indiana.

49 Ariz. H.B. 2471, 53rd Session (2018).

50 Ariz. Rev. Stat. § 14-2518.

51 Ariz. Rev. Stat. § 14-2519

52 Ariz. Rev. Stat. § 14-2520.

53 Ariz. Rev. Stat. §§ 14-2518 - 14-2523.

54 ULC, About the ULC, UniformLaws.org, http://www.uniformlaws.org/aboutulc/overview (last visited Oct. 5, 2019).

55 ULC, Memorandum to Electronic Wills Drafting Committee, UniformLaws.org, https://www.uniformlaws.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=3cb4e4f1-3f38-1e03-2bc1-43c3dabc0af5&forceDialog=0 (last visited Oct. 5, 2019)

56 ULC, Draft Electronic Wills Act for March 2-3 Meeting, UniformLaws.org, https://www.uniformlaws.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=52b77166-bcfe-ca8c-4e78-284605a64781&forceDialog=0 (last visited Oct. 5, 2019).

57 ULC, Uniform Electronic Wills Act, UniformLaws.org, https://www.uniformlaws.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=1dec19cc-1300-7d16-c652-6bb8e5b9d959&forceDialog=0 (last visited Oct. 5, 2019).

58 John H. Langbein, Substantial Compliance with the Wills Act, 88 Harv. L. Rev. 489 (1975).

59 ULC, Uniform Electronic Wills Act, Prefatory Note, UniformLaws.org, https://www.uniformlaws.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=1dec19cc-1300-7d16-c652-6bb8e5b9d959&forceDialog=0 (last visited Oct. 5, 2019).

60 Section 474.360, RSMo 2017.

61 Ohio, for example, recently revised its probate laws to state that in order to be validly executed in another state, the testator must be “physically present” in that state at the time of execution. Ohio Rev. Code § 2107.18.

62 Missouri’s version of the Uniform Electronic Transfers Act specifically excludes “testamentary trusts,” but no mention is made of trusts created during the grantor’s life. Section 432.230, RSMo 2017. Consequently, an argument can be made that such lifetime trusts can already be executed electronically. But given the lack of certainty, additional statutory modifications should be considered.

63 Section 456.4-401, RSMo 2017 et seq.

64 John Bigelow, The Works of Benjamin Franklin, Vol XII (1817).

65 If you would like to be involved in the process of considering electronic will legislation in Missouri, please contact the author.