Confused probate attorney holding a stack of wills

Unconventional Wills and How to Avoid Them 

Unconventional Wills and How to Avoid Them 

December 9, 2025
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If you ever feel unprepared or pressed for time while drafting a will, take heart: history is filled with do-it-yourself wills so unconventional that they serve as a permanent reminder of why clients need you, a lawyer, and not a fender, an eggshell, or a petticoat flounce.  

The Canadian Farmer Who Carved His Will into the Fender of a Tractor 

When Cecil George Harris became trapped underneath his tractor, he knew he was in a life-or-death situation. Determined to ensure his wife would be provided for, he took out his pocketknife and carved his testamentary intentions on the fender of his tractor: “In case I die in this mess I leave all to the wife. Cecil Geo Harris.” Harris was discovered and transported to the hospital, but he eventually succumbed to his injuries.  

The fender was admitted to probate, and the court held that Harris had created a perfectly valid holographic will. This stands today as a striking reminder that while the law can be remarkably accommodating, estate planning is best kept away from heavy machinery and ideally done long before you find yourself in “this mess.”

The River Boat Pilot Who Wrote His Will on an Eggshell 

Delicate? Yes. Enforceable? That’s where things get interesting. This famous UK case is commonly referred to as the “Eggshell Will.” After James Barnes’ death, his widow found “an empty eggshell…perched on top of a wardrobe. On the eggshell, in Barnes’ handwriting…were the words ‘17-1925. Mag. Everything I possess. J.B.’” The court observed that there was no reason why a will couldn’t be written on an eggshell, however, because the writing lacked the required witnesses, it likely failed to qualify as a valid will under English law.  

Still, the case endures as a memorable reminder that while an eggshell may be an acceptable testamentary surface, it is hardly a durable one, and an eggcellent argument for sticking with paper, a time-tested innovation in estate planning that persists for good reason. 

hand holding egg on a dark background

The Man Who Wrote His Will on the Flounce of a Petticoat 

One of the strangest wills involved George W. Hazeltine, widely known as the “hermit of North Broadway.” As reported in the April 1st, 1927 edition of the Los Angeles Examiner, Hazeltine found himself in the hospital at the end of this life with apparently no paper handy. Undeterred, Hazeltine turned to the flounce of Nurse Lillian Pelkey’s petticoat. In 1925 Hazeltine penciled his testamentary wishes, “a roughly scribbled pencil document...full of misspelled words and illiterate phrases” on the flounce of the petticoat, signed it, and had two nurses witness it. 

The “probate of the ‘petticoat will’ was bitterly contested,” but the flounce survived multiple legal challenges. After the court removed the invalid gifts to the nurse-witnesses, Nurse Pelkey’s petticoat was admitted to probate and ultimately accepted as Hazeltine’s valid will. The bulk of the estate passed to his great-grandniece, prompting headlines proclaiming: “Petticoat Will Heiress Wins Estate.” It remains a rare moment in probate history where the court refused to hem and haw. 

All these cases serve a purpose; they remind us that wills are not a do-it-yourself-at-the-last-moment project. Estate planning in advance is a kindness to the people you love and one that goes much more smoothly when your final wishes aren’t scratched on to farm equipment, written on an eggshell, or scribbled onto the flounce of Nurse Pelkey’s petticoat. 

Help Avoid Issues with Wills by Following a Road Map

The 4th edition of Wills Road Map: Practical Considerations in Will Drafting, a guide grounded in clear analysis, practical drafting advice, and the shared desire to prevent precisely the kinds of disasters described above, is now available. If you want your clients’ estate plans to be remembered for their sound judgment and not their headline potential, this edition belongs on your desk. It’s designed to help you navigate the complexities of Texas wills practice with confidence and efficiency. 

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Elizabeth Floreani


Elizabeth is a publications attorney at Texas Bar Books. When she isn’t poring over legal manuals, Elizabeth loves spending time with her husband and children, her three pups, and four hens!

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