In re: Ratzlaff Family Trust.

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1725

In re: Ratzlaff Family Trust.

Filed July 13, 2026
Affirmed
Johnson, Judge

Dakota County District Court
File No. 19HA-CV-23-3347

Michelle K. Kuhl, Lommen Abdo, P.A., Minneapolis, Minnesota; and

David G. Keller, Grannis & Hauge P.A., Eagan, Minnesota (for appellant John G. Ratzlaff)

Erica A. Holzer, Evan A. Nelson, Carly J. Johnson, Maslon L.L.P., Minneapolis,
Minnesota (for respondents Jill Woxland and Angela Brickley)

Considered and decided by Johnson, Presiding Judge; Bond, Judge; and
Chutich, Judge.
∗
NONPRECEDENTIAL OPINION
JOHNSON, Judge
The district court found that a person exerted undue influence over his parents when
they transferred ownership of a lake cabin to him, to the detriment of his two siblings. We
conclude that the district court did not clearly err by finding undue influence. Therefore,
we affirm.

∗Retired justice of the Minnesota Supreme Court, serving as judge of the Minnesota
Court of Appeals by appointment pursuant to Minn. Const. art. VI, § 10, and Minn. Stat.
§ 2.724, subd. 3 (2024).
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FACTS
The facts stated below are drawn from the district court’s findings of fact or from
undisputed evidence in the trial record.
Gerald Ratzlaff and Joan Ratzlaff passed away in August 2024 and March 2025 at
the ages of 90 and 91, respectively. They had three children together: Angela Brickley, Jill
Woxland, and John Ratzlaff.
In the 1980s, Gerald and Joan purchased a cabin on Deer Lake in Itasca County. In
2015, Gerald and Joan created a revocable trust and named their three children as
beneficiaries. Gerald and Joan placed the cabin and their townhome in the trust. In their
later years, Gerald and Joan spent a considerable amount of time at the cabin, especially
during the summertime. Gerald and Joan enjoyed close relationships with their children,
all of whom visited them at the cabin.
In 2018, Gerald fell and broke a leg, which required hospitalization. While he was
in the hospital, John and Jill had an argument about Gerald’s care. In an e-mail message,
John told Jill to “stay away” from him and his wife, including when they were at Gerald
and Joan’s cabin. Before John’s and Jill’s argument, John and his wife visited his parents
approximately once per week or on a biweekly basis. After Gerald’s hospitalization, John
and Angela took turns caring for him at his home. Jill helped her p arents typically only
when John was not present. Angela testified that she felt that she was “not allowed” to
bring meals to her parents or help them because John usually was with them. Angela
explained that her decreased involvement with her parents was “not [by] choice” and that,
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when she offered to help, her parents usually declined because John was available to help
them.
In the summer of 2019, John and his wife spent most weekends at the cabin with
Gerald and Joan. Jill also spent time at Deer Lake in the summertime because she owns a
cabin near her parents ’ cabin. But Gerald and Joan visited Jill’s cabin, and Jill visited
Gerald and Joan, when John was not at the lake. During that summer, John and his wife
expressed interest in buying a cabin for themselves nearby. Gerald and Joan expressed
concern that if John had his own cabin, he no longer would be available to help them.
In August 2019, John asked Angela whether she would consent to a division of
assets that would allow John to receive the cabin, Angela to receive their parents’
townhome in the Twin Cities, and Jill to receive cash. Angela did not give her consent.
By the fall of 2019, John and his wife continued to spend more time with Gerald
and Joan. They visited Gerald and Joan at their Twin Cities townhome four to five times
each week. As a result, Jill did not visit them as often as she had in the past. When the
family got together for Thanksgiving in 2019, John’s wife said that she and John had gone
to look at another cabin. Joan reacted by saying, “Why would you do that when you have
a perfectly good cabin here?”
On two occasions in late 2019, Gerald and Joan met with an attorney (who is Joan’s
first cousin) to discuss a transfer of the cabin to John. On December 17, 2019, John
accompanied Gerald and Joan to a third meeting with the attorney, during which Gerald
and Joan signed documents transferring the cabin from the trust to John. Jill and Angela
did not become aware of the transfer until the following summer.
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In January 2022, Jill and Angela commenced a civil action against John. They
asserted claims of undue influence and duress and requested an order invalidating the cabin
transfer and requiring John to transfer it back to the trust. In April 2023, one day before
trial, John moved to dismiss the case for lack of jurisdiction. In July 2023, the district court
granted the motion and dismissed the case without prejudice.
Jill and Angela commenced this action in August 2023. They again asserted claims
of undue influence and duress and again requested an order invalidating the cabin transfer
and requiring John to transfer it back to the trust. In September 2023, an attorney
representing Gerald filed a letter stating that Gerald, in his capacity as trustee, objected to
the complaint but would defer a decision about whether to join the action. In January 2024,
the district court directed interested parties to seek intervention within 21 days, after which
Gerald filed a formal objection to the complaint. In May 2024, Gerald moved for summary
judgment. He passed away in August 2024, four days before a scheduled hearing on the
motion, which was rescheduled. The attorney who had represented Gerald filed a motion
to substitute John in his capacity as successor trustee. The district court denied the motion
on the ground that John had a conflict of interest. The district court appointed a special
fiduciary to act on behalf of the trust in the lawsuit. The special fiduciary elected not to
pursue the pending summary-judgment motion, which the district court dismissed.
The case was tried to the district court on three days in November 2024 and one day
in April 2025. Joan passed away in March 2025, shortly before the final day of trial. Seven
witnesses testified, and the district court received 27 exhibits, including the transcripts of
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depositions of Gerald and of the attorney who assisted Gerald and Joan in the December
2019 cabin transfer.
In September 2025, the district court filed an order with findings of fact, conclusions
of law, and an order for judgment. The district court concluded that Jill and Angela proved
their claim of undue influence but did not prove their claim of duress. The district court
declared the December 2019 cabin transfer void and ordered John to convey title to the
trust. John appeals.
DECISION
John argues that the evidence presented at trial is insufficient to support a finding of
undue influence and that the district court clearly erred by making such a finding. Jill and
Angela (hereinafter respondents) have jointly filed a responsive brief.
A.
Undue influence is “influence of such a degree exerted upon the testator by another
that it destroys or overcomes the testator’s free agency and substitutes the will of the person
exercising the influence for that of the testator.” In re Wilson’s Estate, 27 N.W.2d 429,
432 (Minn. 1947). A party seeking to prove undue influence must prove that the influence
“was so dominant and controlling of the testator’s mind that . . . he ceased to act of his own
free volition.” In re Reay’s Estate, 81 N.W.2d 277, 280 (Minn. 1957).
The supreme court has observed that “u ndue influence is not usually open and
visible” because it “is commonly exercised behind the scene.” In re Olson’s Estate, 35
N.W.2d 439, 446 (Minn. 1948) (quotation omitted). Accordingly, “undue influence can
usually be shown only by circumstantial evidence.” In re Peterson’s Estate, 168 N.W.2d
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502, 504 (Minn. 1969) . “The existence of undue influence in a particular case is to be
determined by ascertaining the effect of the influence, which in fact was exerted, upon the
testator’s mind, considering his physical and mental condition, the person by whom the
influence was exerted, the time, place, and all the surrounding circumstances thereof.”
Wilson’s Estate, 27 N.W.2d at 432.
Among the factors important as bearing upon the fact of undue
influence are the opportunity to exercise it, active participation
in the preparation of the will by the party exercising it, a
confidential relationship between the person making the will
and the party exercising the influence, disinheritance of those
whom the decedent probably would have remembered in his
will, singularity of the provisions of the will, and the exercise
of influence or persuasion to induce him to make the will in
question.

Id. In addition, the supreme court has identified additional “factors which the courts will
consider in determining whether the grantor’s free will has been overcome,” which include
“age, intelligence, experience, physical and mental health, and strength of character.”
Agner v. Bourn, 161 N.W.2d 813, 818 (Minn. 1968).
While the burden of proving undue influence is upon the party
asserting that it was exercised, the existence of a confidential
relationship makes the burden of proof somewhat simpler.
Where a confidential relationship exists, a showing of an
opportunity to exercise undue influence, an inclination to do
so, and a resulting disposition of property which ignores the
natural recipients is usually sufficient to establish undue
influence.

Norlander v. Cronk, 221 N.W.2d 108, 111-12 (Minn. 1974).
The existence or non-existence of undue influence is a question of fact. Agner, 161
N.W.2d at 819. As a general rule, a district court’s findings of fact “shall not be set aside
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unless clearly erroneous.” Minn. R. Civ. P. 52.01. Findings of fact are clearly erroneous
only if “they are manifestly contrary to the weight of the evidence or not reasonably
supported by the evidence as a whole.” In re Civil Commitment of Kenney, 963 N.W.2d
214, 221 (Minn. 2021) (quotation omitted). Importantly, “an appellate court need not go
into an extended discussion of the evidence to prove or demonstrate the correctness of the
findings of the trial court”; rather, its “duty is fully performed after it has fairly considered
all the evidence and has determined that the evidence reasonably supports the decision. ”
Id. at 222 (quotations omitted). In this specific context, the supreme court has stated that
it “will not set aside the findings of the trial court as to undue influence unless they are
manifestly and palpably contrary to the evidence as a whole.” Reay’s Estate, 81 N.W.2d
at 282.
B.
In this case, the district court expressed its decision in a detailed 32-page order. The
district court made 223 paragraphs of findings of historical fact and organized its analysis
of the evidence with headings that correspond to the so-called Wilson factors. The district
court determined that five of those six factors—opportunity, confidential relationship,
unexpected disinheritance, singularity, and inducement— weighed in favor of a finding of
undue influence and that one factor— active participation—did not weigh either for or
against such a finding.
On appeal, John similarly organizes his principal brief to align with the Wilson
factors. He challenges the district court’s findings on each of the five factors that weighed
in favor of a finding of undue influence, and he argues that a proper analysis of those factors
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compels a finding that he did not exert undue influence over his parents. In effect, John
treats the Wilson factors as a multi-factor balancing test. But we do not interpret Wilson’s
Estate to have prescribed such a test. It appears that the six “factors” listed in that opinion
are examples of “the surrounding circumstances” that may be considered in determining
whether undue influence exists. See Wilson’s Estate, 27 N.W.2d at 432. But the supreme
court has never discussed or applied the Wilson factors in the manner of a multi-factor
balancing test. The supreme court consistently has identified and discussed the most
pertinent evidence in the particular case, without separately analyzing each Wilson factor
and without counting the number of factors weighing for and against a finding of undue
influence. See, e.g., Norlander, 221 N.W.2d at 111-13; In re Peterson’s Estate , 168
N.W.2d at 504 (Minn. 1969); Agner, 161 N.W.2d at 818-23; In re Olson’s Estate, 35
N.W.2d at 446. To be sure, this court sometimes has applied the Wilson factors in the
manner of a multi-factor balancing test. See, e.g., In re Estate of Opsahl, 448 N.W.2d 96,
100-02 (Minn. App. 1989); In re Estate of Overton, 417 N.W.2d 653, 656-58 (Minn. App.
1988); In re Estate of Rechtzigel, 385 N.W.2d 827, 832-34 (Minn. App. 1986); In re Estate
of Anderson, 379 N.W.2d 197, 200-01 (Minn. App. 1985). But this court also has issued
opinions that analyze the issue of undue influence in a manner similar to the supreme court.
See, e.g., In re Estate of Olsen, 357 N.W.2d 407, 412 (Minn. App. 1984). We believe that
the supreme court caselaw does not necessarily require consideration of all six Wilson
factors in every case and does not dictate a particular result based on the number of factors
implicated. See In re Estate of Engman, A16 -0805, 2017 WL 393895, at *4 (Minn. App.
Jan. 30, 2017) (stating that Wilson factors are not multi-factor balancing test); see also
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Minn. R. Civ. App. P. 136.01, subd. 1(c) (providing that nonprecedential opinions are “not
binding authority” but “may be cited as persuasive authority”).
C.
We seek to determine whether the evidentiary record, considered as a whole,
supports the district court’s inferential finding that John exercised undue influence over his
parents when they made the decision to transfer the cabin from the trust to him. The parties
presented conflicting evidence in support of their respective claims and defenses. But the
district court’s findings validate d respondents’ theory of the case. In short, t he district
court found that John visited his parents more often and exerted more control over their
day-to-day lives such that respondents became increasingly isolated from their parents, that
John and his wife expressed an interest in owning a lake cabin, that Gerald and Joan were
concerned that John and his wife would be less available to assist them if they had their
own lake cabin, that John suggested to Angela in August 2019 that the three siblings should
divide their parents’ property in such a manner that he would receive the cabin , and that
Gerald and Joan transferred the cabin to John approximately four months later. Given these
circumstances, the district court found that John exerted undue influence over his parents
when they transferred the cabin from the trust to him.
John argues that the district court clearly erred by finding that a confidential
relationship existed between him and his parents. The district court found a confidential
relationship based on its findings that John was the successor trustee of the trust, that his
parents had granted him a power of attorney, and that he assisted his parents with bill-
paying and medical care. Those findings are supported by the testimony of the parties.
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John testified that he had a power of attorney. He also testified that, starting in 2018, he
took both of his parents to all of their medical appointments, that he continued to do so
“throughout the rest of their lives,” and that he would go over to their home every two
weeks to help with “bills and pills.” John’s relationship with his parents was different from
that of his siblings, who did not have similar responsibilities, apart from providing care
during health crises. Thus, the district court did not clearly err in finding that there was a
confidential relationship between John and his parents.
John also argues that the district court clearly erred by finding that he had an
opportunity to exercise undue influence. The district court based this finding on other
findings that, during the period before the cabin transfer, John had “ample opportunity” to
influence his parents due to his increased role in caring for them, his siblings’ relative
isolation from them, and his mother’s decrease in cognitive functioning. Th ose findings
are supported by the evidence. John testified that he started caring for his parents more in
2018, and he also testified that Joan experienced some cognitive decline before the cabin
transfer. Angela testified that, starting in 2019, she felt like she was “not allowed” to bring
meals to her parents because John already was helping and that he “monopolized their
time,” causing her to decrease her involvement with them. Jill testified that it became more
difficult to visit her parents because of how often John visited. This evidence shows “an
inclination” to “exercise undue influence.” See Norlander, 221 N.W.2d at 112. Thus, the
district court did not clearly err by finding that John had an opportunity to exercise undue
influence.
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John argues further that the district court clearly erred by finding that the cabin
transfer was an “unreasonable disinheritance of” his siblings. This finding is based on a
finding that the cabin transfer “provided [John] a larger portion of the estate than he would
have otherwise received.” John does not dispute that he received a larger share of trust
assets than his siblings, but he contends that the transfer was consistent with his parents ’
desire to keep the cabin in the family. But that contention does not explain why the cabin
should be transferred only to him and not to all three of Gerald and Joan’s children.
The district court discounted Gerald’s explanation of his rationale for the transfer
by finding that he did not understand the legal effect of the transfer. That finding is
supported by Gerald’s deposition testimony that he hoped to “get it back” if John were to
pass away. Notably, Gerald did not testify that he and Joan specifically intended for John
to receive a greater share of their estate than Jill or Angela would receive. Gerald
confirmed that, before the cabin transfer, the estate plan called for each child to receive
one-third of the estate. But when asked whether, when he transferred the cabin, he wanted
John to receive more than one-third of the estate, Gerald answered by saying, “I don’t
know,” and, “It might not be fair enough with the other two kids that John gets an extra
third.” No evidence was introduced concerning the total value of all assets owned by the
trust and Gerald and Jean personally, which may have explained how the cabin transfer
could result in something other than a disproportionate inheritance for John. Accordingly,
the evidence reasonably could be interpreted to reflect a “disposition of property which
ignores the natural recipients.” See Norlander, 221 N.W.2d at 112. Thus, the district court
did not clearly err by finding that there was an unexpected disinheritance.
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John last argues that the district court clearly erred by finding that he induced his
parents to transfer the cabin to him. This finding is based on findings that John “wanted
the cabin,” that he sought to obtain Angela’s consent to a distribution of trust assets that
would leave him with the cabin, that he “increased the frequency at which he visited and
provided parents care to the exclusion of” his siblings, that he was “the only beneficiary of
the family trust present at the meeting when the transfer occurred,” and that his siblings
did not receive similar dispositions of trust assets.
John concedes the district court’s predicate findings; he contends simply that the
evidence do es not compel a finding of inducement. He cites caselaw stating that
“[e]vidence of affection or intimacy as between persons related by blood or marriage
negatives rather than proves undue influence. ” In re Marsden’s Estate, 13 N.W.2d 765,
767 (Minn. 1944). The alleged influencer in Marsden’s Estate was a granddaughter, who
received the bulk of the decedent’s estate, to the detriment of the decedent’s children, “who
had shown but little interest in her welfare except to preserve her estate for themselves.”
Id. at 770-71. In that way, Marsden’s Estate is distinguishable from this case, in which all
three siblings had affection toward and intimacy with their parents. Granted, the mere fact
that John and his parents had mutual affection and intimacy does not, by itself, prove undue
influence. But neither does it provide immunity from a finding of undue influence. This
principle is clear from Olson’s Estate, in which the supreme court recognized the
possibility of undue influence by a relative despite the fact that the testator and the alleged
undue influencer “had a deep and genuine affection for each other, which was manifested
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by his calling her ‘granddaughter and by her calling him grandpa,’ and by acts of service,
kindness, and thoughtfulness for each other.” 35 N.W.2d at 442, 445.
In sum, the district court’s findings are supported by evidence in the trial record.
We must defer to the district court’s opportunity to assess the credibility of the witnesses
and to make findings resolving contested issues. See Minn. R. Civ. P. 52.01 (stating that
“due regard shall be given to the opportunity of the [district] court to judge the credibility
of the witnesses”); Kenney, 963 N.W.2d at 221-23 (stating that appellate court may not
engage in fact-finding, reweigh evidence, make credibility determinations, or reconcile
conflicting evidence). This likely was a close case at trial because the parties presented
different versions of events and gave testimony based on their various perspectives. But
the district court resolved conflicts in the evidence by making findings consistent with
respondents’ theory of undue influence. On appeal, we review the district court’s findings
in a deferential way. As the supreme court wrote in Olson’s Estate, “When the record
reasonably supports the findings at issue on appeal, it is immaterial that the record might
also provide a reasonable basis for inferences and findings to the contrary.” 35 N.W.2d at
444. Accordingly, we conclude that the district court did not clearly err in its findings of
fact and that the evidence is sufficient to support the district court’s judgment.
Affirmed.