(case-by-case analysis required in undue influence cases because they are often proved by circumstantial evidence); Knowlton v. Schultz, 179 Ohio App. 3d 497, 508, 902 N.E.2d 548 (2008) (undue influence usually proved by circumstantial evidence); In re Estate of Johnson, 340 S.W.3d 769, 777 (Tex. App. 2011) (exertion of undue influence is subtle and usually involves extended course of dealings and circumstances; usually established by circumstantial evidence). That necessity of establishing undue influence through circumstantial evidence gave rise to the “suspicious circumstances doctrine” in a common-law claim of undue influence. See Feeney and Carmichael, Will Contests in Kansas, 64 J.K.B.A. 22, 27 (September 1995); see also In re Estate of Maddox, 60 S.W.3d 84, 88 (Tenn. App. 2001) (<HOLDING>). Over a century ago in this state, Sellards v.
holding that an inquiry into trip destination is permissible even in the absence of suspicious circumstances recognizing difficulty in proving conspiracy holding that inquiry notice exists where a reasonable investor of ordinary intelligence would have discovered the suspicious information and recognized it as suspicious recognizing that in most cases proving undue influence must be done circumstantially through the existence of suspicious circumstances recognizing the existence of the special relationship