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American Security & Trust Co. v. Cramer
United States District Court for the District of Columbia
175 F. Supp. 367 (D.D.C. 1959)
When Abraham Hazen died in 1901 he was survived by his widow, his adopted daughter, Hannah, and her two children, Mary and Hugh. After Abraham’s death, Hannah had two more children, Depue and Horace. Abraham’s will had left property in trust for his widow for life, then to Hannah for life, and then to Hannah’s children for their lives. Then, upon the death of each of Hannah’s children, the will provided that each child’s share in the trust would pass to that child’s heirs as determined under the District of Columbia intestacy law. Hannah died one year before Abraham’s widow died, at which point Hannah’s children became life beneficiaries of the trust. When Depue, who was born after Abraham’s death, died in 1954, an action was commenced to determine whether the remainders created by Abraham’s will were valid. A supplemental bill was also filed to determine the validity of the remainder in Horace’s heirs at law, since Horace died while the initial action was pending.
Rule of Law
Holding and Reasoning (Youngdahl, J.)
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