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Undue Influence Case Fades Away at U.S. Supreme Court, But Lessons Endure

The legal saga surrounding the estate of Dr. Laura Dean Head—a respected professor at San Francisco State University—is a powerful example of how undue influence and disinheritance can put an estate at risk and take years to resolve.

Dr. Head, who died in 2013, had disinherited her estranged sisters and named her long-time friend and former student, Zakiya Folami Jendayi, as her sole beneficiary and fiduciary. Over time, Professor Head appointed Jendayi to nearly every fiduciary role available: power of attorney, agent under her Advanced Healthcare Directive, trustee, executor, and sole beneficiary of her estate, which exceeded $2 million. The plan included a no-contest clause intended to prevent challenges.

After her death, Head’s sisters challenged the estate plan alleging undue influence, lack of capacity, and forgery. Now, a dozen years after her death, legal issues surrounding the estate appear to have faded away. Zakiya missed a June deadline to file her petition to the Supreme Court.

[For additional insights, read Undue Influence or Lack of Capacity: Which Theory Fits Your Facts?]

The Original Opinion

California Superior Court Judge Sandra K. Bean invalidated the estate plan, a ruling an appellate court affirmed in October 2024. The state Supreme Court denied review in January 2025. Jendayi took the case to the U.S. Supreme Court, saying in her application for more time to file a petition that the California courts improperly allowed the disinherited heirs to contest the trust. She challenged several other findings, generally stating that the proceedings were tainted with due process violations and bias.

In asking for an extension, Jendayi said she and her attorney were having medical issues, but that she was fighting for everyone who has been “victimized by a legal system that disregards the law, truth, integrity, and the explicit wishes of the deceased.” Jendayi was given until June 15, 2025, to file a complete petition, but the docket falls silent after that.

Trust Was “Presumptively the Product” of Undue Influence

Judge Bean’s ruling serves as an excellent lesson for consumers and estate planners on undue influence. Below are quotes from her opinion on the Probate Department’s findings.

1. Heirs Had Standing to Contest the Trust
“As intestate heirs of Dr. Head, respondents had an actual and concrete interest in Dr. Head’s estate and in invalidating the Trust that purported to disinherit them. Thus, the probate court had broad flexibility to permit respondents to maintain this trust contest in light of their relationship to Dr. Head and the trust estate.”

2. Presumption of Undue Influence Applied
“After hearing argument from the parties, the probate court found the Trust was presumptively the product of Jendayi’s undue influence. It then shifted the burden to Jendayi to affirmatively disprove undue influence.”

3. Dr. Head Was Found to Be Vulnerable
“Dr. Head was terminally ill and placed in hospice care with Jendayi. On the day the Trust was executed, Dr. Head had been rushed to the hospital on an emergency basis and was so ill that Jendayi had to sign a blood transfusion consent form on her behalf.”

4. Jendayi Held Apparent Authority Over Dr. Head
“Jendayi exerted apparent authority as Dr. Head’s power of attorney and ‘controlled Dr. Head’s necessities of life, food, and hospice care.’”

5. Active Participation in Procuring the Trust
“Substantial evidence supported a finding of Jendayi’s active participation in ‘direct[ing] the drafted document to be written out in its final form.’”

6. Undue Benefit to Jendayi
“The court further found that Jendayi unduly benefited from the Trust because it gave her ‘significant assets’ including Dr. Head’s ‘real property which has a current estimated value of $800,000.00 and a claim to [Dr. Head’s] deceased mother’s estate.’”

7. Execution of Trust at Inappropriate Time and Place
“Substantial evidence supported a finding that, in the particular circumstances of this case, the Trust was executed at an inappropriate time and place—i.e., in Dr. Head’s hospital room while she was severely ill.”

Forgery? Bias? Squalor?

Further, the court determined that Dr. Head possessed the contractual capacity to execute the Trust, found no credible evidence of forgery in the process, and rejected the claim of judicial bias. Judge Bean also shared excruciating details that illustrate the dangers of leaving a vulnerable individual without proper care.

During a welfare check in April 2013 police found her in an “uninhabitable” Oakland home infested with opossums, lying in a hoarded room, emaciated, unable to walk, and disoriented. She was hospitalized with multiple serious conditions including cancer, cirrhosis, renal failure, and severe malnutrition. Her treating physician stated she was incapable of caring for herself or managing her affairs, and vulnerable to undue influence. These findings were central to the court’s conclusion that Dr. Head lacked capacity and that Jendayi exerted undue influence during this period.

“The evidence shows that [Jendayi] was a former student and friend who, at best, cared for [Dr. Head] for the last two months of her life,” the court determined. Consequently, the trust was invalidated, and its assets were ordered to be transferred to the special administrator of Dr. Head’s estate.

Conclusion

Fortunately, courts pay close attention to the specter of undue influence, especially when one person serves in multiple roles and benefits significantly, and when the decedent is vulnerable. Independent oversight through neutral witnesses and conducting estate planning in proper settings helps confirm true intentions and strengthens the validity of estate plans.

Should disputes appear to be headed to litigation, individuals should enlist the advice and representation of a firm that dedicates its practice to advocating for clients in complex disputes in court.

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If you have questions about any of the information provided here, contact us or reach out to one of our experienced estate litigation attorneys. You also can call us at 866-330-0578. We look forward to assisting you.


Disclaimer: This article is intended for informational purposes only and does not constitute legal advice. Reading this content does not create an attorney–client relationship. If you have questions about your specific legal situation, you should consult a qualified attorney licensed to practice in your jurisdiction. This content is provided in accordance with the California Rules of Professional Conduct governing attorney advertising and public communications.

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