¶ The Oklahoma Appellant Court held in Estate of Jones v. Miller, 2025 OK CIV APP 29. that a Transfer-on-Death Deed must be signed by the owner of the real property and not by an attorney-in-fact acting under a power of attorney. Here is what the Court sated: “We find that § 1252(A), as the specific statute, must be applied over the general statutory provisions in 16 O.S. § 3 & 58 O.S. § 3027. Consequently, we conclude that the plain and unambiguous meaning of 58 O.S. § 1252(A), demands that a TODD must be “signed by the record owner of interest” in order to effectuate the TODD conveyance. Thus, in the narrow context of an attorney-in-fact that is acting pursuant to a POA, § 1252(A), prohibits a TODD that is not signed by the “record owner”. The Appellant Court went on to hold that in any event the statutory power of attorney used did not grant the right to the attorney-in-fact to create or change a beneficiary designation and, as such, the attorney-in-fact was not authorized to sign the Transfer-On-Death Deed. The Court determined that the property would be subject to probate.