Is a will signed by a person using their electronic signature a valid will in Pennsylvania?

We are living in the digital age. Many people have become familiar with signing agreements of sale and other documents with their digital signatures. But what about a will? Well, about two years ago I prepared wills and other estate planning documents for a fellow attorney and his family. He asked me if his adult child who is serving overseas in the military could sign a valid will with his electronic signature. Based upon cases I had read, I recommended that he should not pursue signing with a digital signature.

Recently, the PA Superior Court provided a definitive answer to this question. In Estate of Kittler, the Superior Court ruled that electronic signature of decedent that was affixed to decedent's purported will through software was insufficient to satisfy the requirement that her will was to be signed at the end of the will because the electronic signature was not a "signature" under 20 Pa. C.S. § 2502. In re Est. of Kittler, 303 A.3d 463, 464