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Naomi Judd Probably Didn’t Disinherit Ashley & Wynonna

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Celebrity estates

Yet another celeb estate is making headlines. This past week, news outlets shared painful news: Naomi Judd left her famous daughters Ashley and Wynonna out of her will.

The problem is, nothing in the reporting suggests that’s the case.

Famous singer Naomi, who died by suicide in April, apparently did have an estate plan that included a will, which one or more reporters viewed.

Naomi’s Executor: Her Spouse

Reports that surfaced focused on just one portion of that will, the one that nominates the executor. They quoted: “I nominate and appoint my spouse, Larry Strickland, as executor of my estate. In the event my spouse ceases or fails to serve, then I nominate and appoint my brother-in-law, Reginald Strickland and Daniel Kris Wiart as co-executors.”

Naomi, 76, was married to Larry for 33 years. There is nothing at all unusual about naming a long-time spouse as executor. It’s the norm. It is somewhat unusual not to name adult children as alternates. But adult children who have busy jobs like actress and country music star aren’t the best candidates.

That’s because being executor doesn’t get you much, it’s just a job. The executor (called Personal Representative in Arizona) merely administers the estate. They gather, maintain, and account for assets; notify and pay creditors; sell property, if appropriate; and pay taxes. And then, after the executor completes those tasks, they distribute the assets to those named in the will. That does not necessarily include them. They may receive no money at all, except sometimes “reasonable compensation” for doing their job. (“Reasonable compensation” for the executor is in Naomi’s will.)

Other Provisions: Normal

Some reports highlighted another part of the will and suggested controversy. The executor has “full authority and discretion” to act without the approval of the court or any beneficiary. This, too, is completely normal and appropriate. It means the executor can carry out all of those tasks of administration efficiently, without having to ask for permission.

Another passage that articles touch on that the document says Naomi was of “sound mind, memory and understanding, and not under any restraint or in any respect incompetent to make a Last Will and Testament.” This, the stories suggest, is dubious because she struggled with mental health. That language typically appears where the witnesses sign, and if, on that day, the witnessed thought she had capacity, there’s no controversy here. Capacity for signing a will is simple. You only need to know 1) the “natural objects of your bounty” – for most people, family members, 2) that you have assets, and 3) that the will affects how your assets go (or do not go) to your people.

That suggests that reporters saw the entire document. But not one reporter who got their hands on the document related the important part: the “dispositive provisions.” That’s where the will directs who actually gets the estate’s assets.

Is There a Trust? Probably

Maybe it just seemed too boring. It may have said something like, “I give and devise the rest and remainder of the estate to the Naomi Judd Trust.” If so, she had what’s known as a “pour over” will. If a person properly sets up their trust, there’s typically no need for these wills. The trust does all the work. The will just catches assets left out. If a trustee discovers non-trust assets, the will acts to collect them and put them (or pour them) into the trust.

In fact, Us Weekly cites a source close to the family as saying both daughters are beneficiaries of Naomi’s Trust. In a typical trust estate plan, any assets governed by the will pay to the trust, and the trust includes all of the dispositive provisions. The insider added: Larry is also the “administrator and head of the Trust, so he really is in control of the whole estate.”

It seems unlikely that Wynonna is “upset,” as sources told It’s possible that she wants to control the estate and trust, but it seems unlikely that the basis is as reported: Because she was part of the duo The Judds and “believes she was a major force behind her mother’s success.” That’s a reason to include them as beneficiary. Not a reason to name them as executor or trustee. Other sources say the reports are mistaken.

Lawsuit May Be the Purpose

Maybe reporters reading the will skipped over the dispositive provisions because they are not relevant. Maybe the will is not transferring assets but serves a different purpose: litigation. A dead person cannot bring a lawsuit. An estate needs to be created to represent their interest.

It seems that’s why Naomi’s pourover will surfaced. Her estate and family members filed a lawsuit asking to keep records related to her suicide confidential. The lawsuit asks to block the release of photographs and video officials took at the scene. A judge granted temporary relief and set another hearing for September 12.

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Robert B. Fleming


Robert Fleming is a Fellow of both the American College of Trust and Estate Counsel and the National Academy of Elder Law Attorneys. He has been certified as a Specialist in Estate and Trust Law by the State Bar of Arizona‘s Board of Legal Specialization, and he is also a Certified Elder Law Attorney by the National Elder Law Foundation. Robert has a long history of involvement in local, state and national organizations. He is most proud of his instrumental involvement in the Special Needs Alliance, the premier national organization for lawyers dealing with special needs trusts and planning.

Robert has two adult children, two young grandchildren and a wife of over fifty years. He is devoted to all of them. He is also very fond of Rosalind Franklin (his office companion corgi), and his homebound cat Muninn. He just likes people, their pets and their stories.

Elizabeth N.R. Friman


Elizabeth Noble Rollings Friman is a principal and licensed fiduciary at Fleming & Curti, PLC. Elizabeth enjoys estate planning and helping families navigate trust and probate administrations. She is passionate about the fiduciary work that she performs as a trustee, personal representative, guardian, and conservator. Elizabeth works with CPAs, financial professionals, case managers, and medical providers to tailor solutions to complex family challenges. Elizabeth is often called upon to serve as a neutral party so that families can avoid protracted legal conflict. Elizabeth relies on the expertise of her team at Fleming & Curti, and as the Firm approaches its third decade, she is proud of the culture of care and consideration that the Firm embodies. Finding workable solutions to sensitive and complex family challenges is something that Elizabeth and the Fleming & Curti team do well.

Amy F. Matheson


Amy Farrell Matheson has worked as an attorney at Fleming & Curti since 2006. A member of the Southern Arizona Estate Planning Council, she is primarily responsible for estate planning and probate matters.

Amy graduated from Wellesley College with a double major in political science and English. She is an honors graduate of Suffolk University Law School and has been admitted to practice in Arizona, Massachusetts, New York, and the District of Columbia.

Prior to joining Fleming & Curti, Amy worked for American Public Television in Boston, and with the international trade group at White & Case, LLP, in Washington, D.C.

Amy’s husband, Tom, is an astronomer at NOIRLab and the Head of Time Domain Services, whose main project is ANTARES. Sadly, this does not involve actual time travel. Amy’s twin daughters are high school students; Finn, her Irish Red and White Setter, remains a puppy at heart.

Famous people's wills

Matthew M. Mansour


Matthew is a law clerk who recently earned his law degree from the University of Arizona James E. Rogers College of Law. His undergraduate degree is in psychology from the University of California, Santa Barbara. Matthew has had a passion for advocacy in the Tucson community since his time as a law student representative in the Workers’ Rights Clinic. He also has worked in both the Pima County Attorney’s Office and the Pima County Public Defender’s Office. He enjoys playing basketball, caring for his cat, and listening to audiobooks narrated by the authors.