Xi Zhao v. Tai-Shing Wong

*1201 Opinion

In this case we review the trial court’s decision that a document containing eight words, seven of them proper names and an appellation, constituted a holographic will.

Tai-Kin Wong (Tai) was a successful 44-year-old businessman who until just before death had a history of good health. He was living with his girlfriend Xi Zhao (Xi), and he enjoyed a close and loving relationship with his large family. On New Year’s Eve in 1992, he took ill and died in a hospital emergency room of unexplained causes. Sometime after his death, found in his office was a sealed envelope, decorated with stickers and containing a handwritten note which read “All Tai-Kin Wong’s —> Xi Zhao, my best half TKW 12-31-92.” This document—containing no subject, no verb, no description of property, and no indication of its subject matter or purpose—was found by the trial court to be a holographic will, passing Tai’s entire estate to Xi. Tai’s father, Kok-Cheong Wong (appellant) 1 brought this appeal. For the reasons stated below, we will reverse the judgment.

Facts and Procedural History

At the time of his death, Tai was 44 years old. He had never married and he had no children. For the previous…