Abrams v. Templeton
South Carolina Court of Appeals
465 S.E.2d 117 (1995)
In 1914, testator Mary Ann Taylor Ramage executed a will which devised a 160-acre tract of land to her husband for life, then to her son Albert for life, then to her son’s children for life, and then remainder to their children (her great-grandchildren). Mary Ann was survived by her husband, Albert, and various grandchildren. The will also devised another 130 acres to her daughter Alma Templeton’s children. Templeton’s heirs (plaintiffs) argued that the gift to Albert’s grandchildren violated the rule against perpetuities and that therefore, because Albert’s children only held life estates, the property would revert to Mary Ann to be distributed through intestate succession. The trial judge determined that the gift to her great-grandchildren violated the rule against perpetuities. However, as mandated by South Carolina’s reform statute, the judge inserted a savings clause that enabled the gift to comply with the rule against perpetuities while maintaining the testator’s intent, which was to benefit the two “branches” of her family equally.
Rule of Law
Holding and Reasoning (Hearn, J.)
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