Hynson v. Jeffries

Robert Hynson owned oil and gas rights in a tract of land. In his will, he created a trust and left for the trust all of his oil and gas interests. Specifically, the will stated: “All of the income of the trust shall be paid to my said wife during her lifetime.” The will also stated that upon the death of Hynson’s wife, Carolyn, the remainder would be split evenly among (1) the descendants of Carolyn, (2) the descendants of Hynson’s daughter, Julie Jeffries, and (3) the descendants of Hynson’s son. Upon Hynson’s death, his wife, Carolyn, asserted that she was entitled to all royalty payments under the income clause in the will. Carolyn’s argument was based on the text of the will, the open mines doctrine, and Mississippi’s Uniform Principal and Income Law (UPIL). The UPIL applied “[i]n the absence of any contrary terms in the trust instrument.” The UPIL stated that 27.5 percent of gross receipts if received as royalties “shall be added to principal as an allowance for depletion.” John Jeffries, a trustee of the trust, took the position that the royalties should be invested for the remaindermen, and that Carolyn was only entitled to receive interest from those investments. The trial court held that the UPIL did not apply, because the language of the will was clear as defined by the common law. The court held that Carolyn, as life tenant, was only entitled to receive interest on royalties. Carolyn appealed.