[Bruiser] Samuel, a Ninety-Year-Old Wild Bronco Rider in the Rodeo

Multiple Choice

[Bruiser] Samuel, a ninety-year-old wild bronco rider in the rodeo, had a will leaving all his possessions to a girlfriend, Winona, age twenty-two. During a rodeo, Samuel was placed on a particularly wild bronco named "Bruiser." During the ride, Crabby the clown yelled out to Samuel that Winona had suggested that particular horse. Samuel was annoyed about that because he was having trouble controlling Bruiser. Nevertheless, Samuel prevailed and collected the prize. Samuel was so excited that he had a heart attack. Just before he died, he yelled out, "Winona, you had me put on that crazy horse, and I'm revoking my will. I'm dying, and I'm leaving everything to my other girlfriend, Keisha." A number of witnesses heard his statement; and Crabby, who had always liked Keisha more than Winona, promptly wrote down Samuel's statement. Winona knew nothing about Keisha and was very upset. She told Keisha that Keisha could have nothing because Samuel's written will was still in effect. She also told Keisha that Samuel was suffering from a mental illness and did not know what he was doing when he stated that Keisha should take everything. Samuel's daughter, Laura, age 65, also entered the discussion stating that Winona had unfairly coerced Samuel into writing a will leaving her everything.
-What was the effect of Samuel's statement that Keisha should take everything, assuming he was of sound mind?

A) Because a will must be in writing, his statement has no effect.
B) Because a will is not usually required to be in writing, his statement was effective to revoke any prior will.
C) His statement was ineffective to revoke his prior will only because he was angry when he made it.
D) His statement was ineffective to revoke his prior will only because he believed he was dying at the time he made it.
E) His statement would likely be upheld as an oral will because he made the statement during his last illness in front of witnesses who later wrote down his wishes.