An Arkansas appeals court invalidated a will that left all of a decedent's assets to a cult leader.
The leader had convinced the decedent that he had supernatural powers, that he could transmigrate, did not have to eat or perform other bodily functions, and had the power to heal. He refrained from displaying his powers openly, however, because it would cause people to "focus on his miracles rather than upon his teachings."
The leader also warned the decedent that "bad things" would happen to her if she did not give more and more of her money to him. She began giving up to 75% of her earnings as a nurse to the leader, executed a will leaving her entire estate to him, and assigned several life insurance policies to him.
After her untimely death in an accident, a lawsuit was filed on behalf of her minor child seeking to invalidate the will and life insurance beneficiary designations on the basis of undue influence. The lawsuit alleged that the decedent had been so unduly influenced by the leader that her actions were not the product of her own free will and therefore should be invalidated.
The court agreed that the decedent had been unduly influenced by the cult leader, and accordingly invalidated the transfer of assets to him. It noted that the leader was a very skillful manipulator of emotionally immature and dependent persons, and that he "virtually enslaved" the decedent through manipulation of her mind and emotions. Carpenter v. Horace Mann Life Insurance Co., 730 S.W.2d 502 (Ark. App. 1987).
