SHEILA NIEBURG EDELSTEIN
v.
ERIC W. SULZBERGER, ET AL.

Fla. 3d DCA | 2025-04-16
No. 2023-2262
Lopez, J., Fernandez, J., Lindsey, J., Miller, J.
2025 FL 3192 Florida District Court of Appeal, Third District (2025)

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Holding

The probate of a will in Florida is conclusive of its due execution, the testator's competency, and freedom from fraud, duress, mistake, and undue influence in any collateral action relating to devised property.


Headnotes

[1] The probate of a will in Florida is conclusive in any collateral action or proceeding relating to devised property as to the will's due execution, the testator's competen…

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Key Quotes

“In any collateral action or proceeding relating to devised property, the probate of a will in Florida shall be conclusive of its due execution; that it was executed by a competent testator, free of fraud, duress, mistake, and undue influence; and that the will was unrevoked on the testator's death.”

Statutory basis for the court's affirmance, citing § 733.103(2), Fla. Stat. (2024)

Facts & Procedural History

Sheila Nieburg Edelstein appealed a circuit court judgment in a matter involving a will and devised property. The case involved a dispute concerning t…

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Opinion of the Court
Miller

Third District Court of Appeal State of Florida

Opinion filed April 16, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-2262 Lower Tribunal No. 11-37956 ________________

Sheila Nieburg Edelstein, Appellant,

vs.

Eric W. Sulzberger, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Peter R. Lopez, Judge.

The Mineo Salcedo Law Firm, and Peter Mineo, Jr. (Davie); Moore Rabinowitz Law, and Adam G. Rabinowitz (Plantation), for appellant.

Cruser, Mitchell, Novitz, Sanchez, Gaston & Zimet LLP, and Kenneth

R. Drake and Brandt Roen, for appellee Eric W. Sulzberger.

Before FERNANDEZ, LINDSEY, and MILLER, JJ.

PER CURIAM.

2 Affirmed. See § 733.103(2), Fla. Stat. (2024) (“In any collateral action or proceeding relating to devised property, the probate of a will in Florida shall be conclusive of its due execution; that it was executed by a competent testator, free of fraud, duress, mistake, and undue influence; and that the will was unrevoked on the testator’s death.”).


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