Carroll v. Hill, No. 21-3885 (6th Cir. 2022)
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Born in 1967, Carroll was raised by a single mother near Albert Barber's property. Albert’s younger sister was Arlene. Albert died in 1998. . In 2000, Arlene informed the Geauga County Probate Court that she had lost Albert’s will and possessed only an unsigned copy. She filed an application to probate the will. The court found that all interested parties were given appropriate notice and admitted the will. The court distributed most of the estate— land worth $232,000 and slightly over $30,000 in other assets—to Arlene under the will.
Carroll claims that in 2018, Arlene told her that Albert was Carroll’s father. Carrol sued, claiming that Arlene submitted an invalid version of Albert’s will to an Ohio probate court and that she should have inherited Albert’s estate. The district court concluded that she lacked standing and that the probate exception to federal jurisdiction barred it from hearing her claims. The Sixth Circuit affirmed, citing her lack of standing. Carroll has not plausibly pleaded that the Barbers’ misconduct injured her, that they left her any worse off. Even given an opportunity to contest Albert’s will, Carroll would not have been eligible to contest Albert’s will under Ohio law when he died.
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