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Knupp v. District of Columbia
District of Columbia Court of Appeals (1990) | 578 A.2d 702; 1990 D.C. App. LEXIS 181; 1990 WL 109607
TL;DR: A will referenced a paragraph to name the residual beneficiary, but that paragraph was blank. The court refused to admit extrinsic evidence to fill in the missing name, causing the estate to pass to the government by escheat.
Legal Significance: This case reinforces the traditional, strict rule that courts may use extrinsic evidence to interpret ambiguous terms in a will but cannot use it to reform a will by adding a completely omitted beneficiary, even with clear evidence of a scrivener's error.