In the recent case of Kim v. Kim, the Virginia Supreme Court addresses the "benefit" element of the test for presumed undue influence. The “benefit,” it seems, can be indirect; however, it must be “immediate,” “express,” or not too “uncertain and contingent.”

In Irving v. DiVito [http://www.courts.state.va.us/opinions/opnscvwp/1170071.pdf], the Virginia Supreme Court determined the circuit court did not err in refusing to admit to probate a writing offered as a holographic codicil. The writing at issue in Irving is clear about the intended dispositive