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A.R.S. § 14-3407

Burden of Proof in Contested Probate Cases

Verified April 4, 2026 • 57th Legislature, 1st Regular Session

When someone challenges a will in formal testacy proceedings, Arizona law assigns specific burdens of proof. A person claiming intestacy must prove death, venue, and heirship. A person offering a will for probate must prove death and venue. If both sides present claims, the court decides the will question first.

Title 14, PROBATE OF WILLS AND ADMINISTRATION

azleg.gov

Who Must Prove What

In a contested formal testacy proceeding, the burden of proof depends on what each party is asking the court to do. The person petitioning for intestacy (claiming there is no valid will) carries one set of responsibilities. The person seeking to admit a will to probate carries another.

In contested cases, petitioners who seek to establish intestacy have the burden of establishing prima facie proof of death, venue and heirship. Proponents of a will, if they are also petitioners, have the burden of establishing prima facie proof of death and venue.

A.R.S. § 14-3407

Notice the difference: the person claiming intestacy must prove heirship (their relationship to the deceased), while the will proponent does not. This makes sense because the will itself identifies the beneficiaries. The will proponent needs to show that the deceased has passed away and that the case is filed in the right county.

The Will Gets Decided First

When a contested case involves both a will offered for probate and a competing claim of intestacy, Arizona law sets a clear order of operations. The court determines whether the will is entitled to probate before addressing any intestacy claims.

If a will is opposed by a petition for a declaration of intestacy, it shall be determined first whether the will is entitled to probate.

A.R.S. § 14-3407

This priority makes practical sense. If the court validates the will, the intestacy question becomes moot. If the will is found invalid, the court then moves on to determine heirship under Arizona's intestacy laws. This structured approach prevents the court from resolving inheritance questions before knowing whether a valid will controls the distribution.

In contested cases, petitioners who seek to establish intestacy have the burden of establishing prima facie proof of death, venue and heirship. Proponents of a will, if they are also petitioners, have the burden of establishing prima facie proof of death and venue. If a will is opposed by a petition for a declaration of intestacy, it shall be determined first whether the will is entitled to probate.
View on azleg.gov

This page provides general legal information about Arizona statutes and is not legal advice. For guidance on how this law applies to your situation, speak with a qualified attorney.

Related Questions

What is probate, and how long does it take in Arizona?

Probate is a court-supervised process that validates a will, pays debts, and distributes assets. In Arizona, it typically takes 8 to 12 months and costs $10,000 to $15,000 in fees.

What happens if I die without a will in Arizona?

Without a will in Arizona, your assets are distributed according to state intestacy laws. The court decides who receives your property using a fixed formula based on family relationships.

Can someone contest my will or trust in Arizona?

Both wills and trusts can be contested in Arizona, but trusts are much harder to challenge because they do not go through probate. A challenger must file a new lawsuit and prove compelling grounds, and no-contest clauses can discourage frivolous challenges.

Related Statutes

§ 14-3405Formal Testacy Proceedings: How Uncontested Cases Are Handled
§ 14-3406Contested Will Cases: When Witness Testimony Is Required
§ 14-3409Formal Testacy Orders: What the Court Must Find Before Probating a Will

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