Dravo Estate

16 Pa. D. & C.2d 106
CourtPennsylvania Orphans' Court, Allegheny County
DecidedDecember 6, 1957
DocketNo. 2; no. 1149 A1 of 1942
StatusPublished
Cited by1 cases

This text of 16 Pa. D. & C.2d 106 (Dravo Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Allegheny County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dravo Estate, 16 Pa. D. & C.2d 106 (Pa. Super. Ct. 1957).

Opinion

Boyle, P. J.,

— The question which is before the court for determination in the audits of three separate accounts in two inter vivos trusts and a testamentary trust containing identical trust provisions for the benefit of Donald Pettit, his widow and issue, is whether the said provision violates the common law rule against perpetuities, the three trusts having been created prior to January 1,1948, the effective date of the Estates Act of April 24,1947, P. L. 100.

The two irrevocable inter vivos trusts were created by separate trust instruments executed by Francis R. Dravo and his wife, Fanny M. Dravo, on January 17, 1931. The testamentary trust was created by the will of Francis R. Dravo which was signed by testator on February 20, 1933, and became effective upon his death on February 25, 1934. Fanny M. Dravo died on December 11, 1953. These settlors and testator had no children.

[108]*108The trust instruments and the will referred to contain trust provisions for reciprocal life estates for settlors, for certain employes of the Dravo Corporation, for a number of charities and for certain of the relatives of settlors. Among these relatives was a nephew, Donald Pettit. As to him the two trust inter vivos instruments and the will contain provisions in identical language giving him the net income from varying shares in each trust for his life and providing that . . upon his death the income from said . . . share shall be paid to his widow during her life. At the death of Donald Pettit and his wife, the principar of said .. . share shall be paid in equal shares to any issue of his who are then living, per stirpes. If the said Donald Pettit and his wife should die without issue surviving them, the principal of the said share shall be paid to St. Stephen’s Church, Sewickley, Pennsylvania.”

Donald Pettit, the nephew, and his first wife, Jane D. Pettit, were married on June 24, 1922. A son, William D. Pettit, now living, was born of this marriage on May 23,1923. The child William was seven years of age when the two inter vivos trusts were created and was 10 years of age at the death of Francis R. Dravo. The marriage of Donald and Jane Pettit was attended by serious difficulties from the beginning. It is conceded that settlors and testator endeavored to assist their nephew Donald by providing employment for him and it is acknowledged that they had an affectionate regard for his wife Jane and the child William.

The marriage of Donald Pettit and Jane D. Pettit was dissolved by a decree in divorce on December 31, 1934. In 1937 Donald Pettit married Elizabeth Clark who thus became his second wife. She had been bom on January 14,1899, during the lifetimes of Francis R. Dravo and Fanny M. Dravo, the creators of the three trusts involved in the case at bar.

[109]*109No children were born' of the second marriage of Donald Pettit.

Elizabeth Clark, the second wife of Donald Pettit, died on June 10, 1956.

Donald Pettit, the first life tenant under the three trusts, died on March 13, 1957. He is survived by his first wife, Jane D. Pettit, and his son, William D. Pet-tit, born of his marriage with Jane.

Upon the death of Donald Pettit the trustees in the three trusts filed the accounts which are now on audit. In each instance the same questions of distribution are presented:

Under the language of the trust instruments is Jane, the surviving first wife of Donald, entitled to receive the income from the trusts for her life? Is she disqualified as a life tenant by reason of the 1934 divorce? What are the rights of the son, William D. Pettit, at this time? Does he have a present vested interest in the trust estate by reason of his father’s death? Is the interest of William D. Pettit a contingent one under the language of the trust instruments? Do the respective provisions for William D. Pettit violate the common law rule against perpetuities as the executors of the will of Fanny M. Dravo contend? What is the intention of settlors?

The rights of Jane, the surviving first wife, and her son, William D. Pettit, are interrelated and depend upon the construction of the gifts to the “widow” or “wife” of Donald. If an absolute gift of a life estate was made to the person who met the description of “wife” at the execution of the instruments (Jane D. Pettit), changed circumstances such as the subsequent divorce would not affect the gift to her. Thus William’s contingent gift, which would vest at the end of Jane’s life estate, could not violate the rule against perpetuities, for it would vest at the death of a life in being at [110]*110the effective date of the instruments: Lippincott’s Estate, 333 Pa. 48, 54 (1939); Solms’ Estate, 253 Pa. 293, 296 (1916); Anshutz v. Miller, 81 Pa. 212, 215 (1876); Harrigan Estate, 72 D. & C. 441, 442 (1950); Batchelor Estate, 67 D. & C. 310, 318 (1949 Hunter, J.); Disston’s Estate, 46 D. & C. 496, 498 (1942), affirmed on other grounds, 349 Pa. 129; Sharpe’s Estate, 15 W. N. C. 419, 420 (1884 wife named); 1 Simes and Smith, The Law of Future Interests, §153, pp. 185-86.

If, however, the word “widow” was used not to identify Jane but as a condition to the gift, restricting it to Donald’s wife alive at his death, then Jane could not take the contingent life estate, for she is not Donald’s widow because of the divorce. In this event, William could claim nothing because his contingent gift, vesting at the death of the surviving widow (a person possibly unborn at the creation of the trusts), might vest beyond the period of the common law rule against perpetuities:

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Bluebook (online)
16 Pa. D. & C.2d 106, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dravo-estate-paorphctallegh-1957.