Signing a sticky note “XO” does not satisfy the signature requirement for a valid holographic will. When Jamie Bixby died, she left behind two sticky notes on a coffee table. One note stated: “I’m sorry, I just don’t have the tools for this. Beth gets everything.” The second note stated: Also, sorry universe, thank you for the experience. . . . maybe XO.” The trial court ruled that the purported will lacked a signature. The court of appeals agreed. “XO” is not a signature in the usual sense and is a common abbreviation for “hugs and kisses.” The court of appeals consulted an online dictionary, the Cambridge Dictionary, and the Oxford Dictionary.  An X by itself has been used and accepted as a signature, the court explained, but under those circumstances, the nature of the mark and its context suggested the mark had been placed with “signatory intent.” Since XO does not show signatory intent, the court need not consider “testamentary intent.” Way too much time, energy, and research were spent on drafting this opinion. Reaching an opposite result would have been absurd, so why not write a two sentence decision: “The court below correctly determined that XO written on the bottom of a sticky note does not meet the signature requirement for a holographic will. We agree; judgment affirmed.” 

link to opinion