In the case of Aldrich v. Aldrich, a dispute arose over the interpretation of a holographic will (a will that has been entirely handwritten and signed by the testator). The decedent, Mrs. Annie Lou Godfrey Aldrich, had written her own will in which she listed specific assets to be given to her brother, Avery Lawrence. However, after writing this document but before her death, she acquired additional property not mentioned in the original text. Upon Mrs. Aldrich's passing away without having revised or updated her will to include these new properties; Mr.Lawrence and two nieces from another deceased sibling claimed rights over them. The Supreme Court was tasked with determining who should inherit these unmentioned assets: whether they should go to Mr.Lawrence as per Florida’s law on intestate succession (which would apply if there were no valid testamentary provision) or whether they should be divided among all surviving family members according to common-law rules for interpreting documents. Ultimately,the court ruled against Mr.Lawrence stating that "the intention expressed in such [holographic] instrument must prevail" meaning that only those items specifically mentioned in Ms.Aldrich's handwritten note could pass onto him while remaining estate would follow normal probate process.

In the dissenting opinion for Aldrich v. Aldrich, Justice Harlan disagreed with the majority's interpretation of Florida law regarding holographic wills and intestacy. He argued that under Florida law, a testator who writes a will without naming an executor or providing for all their property does not necessarily intend to die partially intestate. Instead, he suggested that such omissions could be due to oversight or misunderstanding about how estate laws work. Therefore, in his view, it was inappropriate for the Court to assume that Ms. Aldrich intended her nieces rather than her brother (the residuary legatee) to inherit any property she acquired after writing her will but did not specifically mention in it.