Court of Chancery Grants Motion to Dismiss Based on Plaintiff’s Lack of Standing
Eugenia Cole v. Simone Rayfield, Executor, C.A. No. 2025-1091-SEM (December 8, 2025)
In a recent decision, the Delaware Court of Chancery dismissed a pro se action seeking to halt the sale of estate property, holding that the plaintiff lacked standing to challenge the executor’s administration of the estate. Eugenia Cole (the “Plaintiff”) filed suit against the executrix of her brother’s estate (the “Estate”), alleging the executrix Defendant engaged in self-dealing. The Plaintiff argued that a private sale of the decedent’s residence violated the will’s directive that the property be sold “as soon as practicable.”
The court found that standing was a threshold issue dispositive of the case. Under the decedent’s 2018 will and operative 2024 codicil, the Defendant was properly appointed as executrix and several named individuals were designated as beneficiaries. Plaintiff was not a beneficiary, creditor, or executor of the Estate, nor did she have any pecuniary interest in the Estate. As a result, she could not show an injury in fact or a legally cognizable interest in the Estate sufficient to challenge the Estate’s administration.
Plaintiff’s attempt to establish standing by relying on a purported prior addendum to the will also failed. The court held that the unsigned and unwitnessed addendum did not satisfy Delaware statutory requirements for a valid codicil and thus was not valid nor enforceable. The court concluded that the Plaintiff lacked standing to seek any relief relating to Defendant’s administration of the Estate. Plaintiff’s complaint was dismissed in full, and the order was entered as a final report under Court of Chancery Rule 144.
