Overturning a 1965 decision holding that extrinsic evidence was inadmissible to reform a will that is unambiguous on its face, a unanimous Supreme Court of California has held that an unambiguous will may be reformed to conform to the testator’s intent if the claimants establish by clear and convincing evidence that the will contains a mistake of intent and also establish the testator’s actual specific intent at the time the will was drafted. The Court says it is joining a small but growing number of states that are modernizing their rules to more accurately fulfill the testator’s intent. ( Estate of Duke , Sup. Ct., CA, No. S199435, 7/25/15. ) The issue arose in a case involving the estate...