53 A.2d 205 (N.J. Prerog. Ct. 1947), aff'd, 54 A.2d 205 (N.J. 1947) (per curiam)
In re Strittmater is one of the most discussed American will-capacity cases, not only for its doctrinal statement on insane delusions and testamentary capacity, but also for the way the court's reasoning reflects the gendered assumptions of its time. The testatrix—an ardent feminist who left her estate to the National Woman's Party—was found to have suffered from paranoia and pathological hatred of men.
Whether a will is invalid for lack of testamentary capacity where the testatrix, although capable in ordinary affairs, suffered from insane delusions—here, a pathological hatred associated with paranoia—that materially affected the testamentary disposition.
A testator possesses testamentary capacity if, at the time of execution, she understands (1) the nature of making a will, (2) the general nature and extent of her property, (3) the natural objects of her bounty, and (4) the disposition she is making. However, even where these elements are generally met, a will is invalid if it is the product of an insane delusion—i.e., a false belief with no reasonable basis, adhered to against reason and evidence—that materially affects or determines the testamentary disposition. The burden to prove lack of capacity or the presence of an insane delusion rests on the will contestant.
The court held that Strittmater lacked testamentary capacity because her will was the product of insane delusions stemming from paranoia and a pathological hatred that materially influenced her decision to leave her estate to the National Woman's Party; the will was therefore set aside and the estate passed by intestacy to her relatives. The decision was affirmed on appeal.
Doctrinally, Strittmater is a leading case on the insane delusion doctrine as a discrete ground for invalidating wills separate from general testamentary capacity and undue influence. Pedagogically, it highlights how courts sift between eccentric or unpopular beliefs (which do not defeat capacity) and delusions that materially drive testamentary choices (which do). Normatively, the case is often criticized for conflating fervent feminism with mental illness, underscoring the role of judicial values and the risk of bias when courts evaluate a testator's motives. Modern courts tend to approach political or ideological bequests more cautiously, requiring clear proof that any mental illness, not mere controversial beliefs, dictated the disposition.