American Security & Trust Co. v. Cramer (1959)
Facts. Hazen bequeathed property in a trust to his wife for life, then to his “adopted daughter Hannah for life, then to Hannah’s children for their lives. “Upon the death of each [child] the share of the one so dying shall go absolutely to the persons who shall then be her or his heirs at law.” At the time the gift was created, Hannah had two children, Mary and Hugh. After Hazen’s death, Hannah bore Depue and Horace.
Whether a subclass exists where a will makes a gift to each child’s heirs upon the death of each child?
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