rule against perpetuities
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The rule against perpetuities is a legal rule in the American common law that prevents people from using legal instruments (usually a
deed In common law, a deed is any legal instrument in writing which passes, affirms or confirms an interest, right, or property and that is signed, attested, delivered, and in some jurisdiction (area), jurisdictions, seal (emblem), sealed. It is com ...
or a
will Will may refer to: Common meanings * Will and testament A will or testament is a legal document that expresses a person's (testator) wishes as to how their property (estate (law), estate) is to be distributed after their death and as to which ...
) to exert control over the ownership of
private property Private property is a legal designation for the ownership of property by non-governmental legal entities. Private property is distinguishable from public property and personal property, which is owned by a state entity, and from collective ...
for a time long beyond the lives of people living at the time the instrument was written. Specifically, the rule forbids a person from creating future interests (traditionally contingent remainders and executory interests) in property that would vest beyond 21 years after the lifetimes of those living at the time of creation of the interest, often expressed as a “life in being plus twenty-one years”. In essence, the rule prevents a person from putting qualifications and criteria in a deed or a will that would continue to affect the ownership of property long after he or she has died, a concept often referred to as control by the "dead hand" or "''
mortmain Mortmain () is the perpetual, inalienable ownership of real estate by a company (law), corporation or legal institution; the term is usually used in the context of its prohibition. Historically, the land owner usually would be the religious off ...
''". The basic elements of the rule against perpetuities originated in England in the 17th century and were "crystallized" into a single rule in the 19th century. The rule's classic formulation was given in 1886 by the American legal scholar
John Chipman Gray John Chipman Gray (July 14, 1839February 25, 1915) was an American scholar of property law and professor at Harvard Law School. He also founded the law firm Ropes & Gray, with law partner John Codman Ropes. He was half-brother to Supreme Court of ...
: The rule against perpetuities serves a number of purposes. First, English courts have long recognized that allowing owners to attach long-lasting contingencies to their property harms the ability of future generations to freely buy and sell the property, since few people would be willing to buy property that had unresolved issues regarding its ownership hanging over it. Second, judges often had concerns about the dead being able to impose excessive limitations on the ownership and use of property by those still living. For this reason, the rule only allows testators (will-makers) to put contingencies on ownership upon the following generation plus 21 years. Lastly, the rule against perpetuities was sometimes used to prevent very large, possibly aristocratic estates from being kept in one family for more than one or two generations at a time. The rule also applies to options to acquire property. Often, one of the objectives of delaying the time of
vesting In law Law is a set of rules that are created and are law enforcement, enforceable by social or governmental institutions to regulate behavior,Robertson, ''Crimes against humanity'', 90. with its precise definition a matter of longstandin ...
is to avoid or reduce taxation of some sort. For example, a bequest in a will may be to one’s grandchildren, often with a life interest to one’s surviving spouse and then to the children, to avoid the payment of multiple death duties or inheritance taxes on the testator’s estate. The rule against perpetuities was one of the devices developed to at least limit this
tax avoidance Tax avoidance is the legal usage of the tax regime in a single territory to one's own advantage to reduce the amount of tax that is payable by means that are within the law. A tax shelter is one type of tax avoidance, and tax havens are jurisd ...
strategy.


Historical background

The rule has its origin in the '' Duke of Norfolk's Case'' of 1682. That case concerned Henry, 22nd Earl of Arundel, who had tried to create a shifting executory limitation so that some of his property would pass to his eldest son (who was mentally deficient) and then to his second son, and other property would pass to his second son, but then to his fourth son. The estate plan also included provisions for shifting property many generations later if certain conditions should occur. When his second son, Henry, succeeded to his elder brother's property, he did not want to pass the other property to his younger brother, Charles. Charles sued to enforce his interest, and the court (in this instance, the
House of Lords The House of Lords, also known as the House of Peers, is the Bicameralism, upper house of the Parliament of the United Kingdom. Membership is by Life peer, appointment, Hereditary peer, heredity or Lords Spiritual, official function. Like the ...
) held that such a shifting condition could not exist indefinitely. The judges believed that tying up property too long beyond the lives of people living at the time was wrong, although the exact period was not determined until another case, '' Cadell v. Palmer'', 150 years later. The rule against perpetuities is closely related to another doctrine in the common law of property, the rule against unreasonable restraints on alienation. Both stem from an underlying principle or reference in the common law disapproving of restraints on property rights. However, while a violation of the rule against perpetuities is also a violation of the rule against unreasonable restraints on alienation, the reciprocal is not true. As one has stated, "The rule against perpetuities is an ancient, but still vital, rule of property law intended to enhance marketability of property interests by limiting remoteness of vesting." For this reason, another court has declared that the provisions of the rule are predicated upon "public policy" and thus "constitute non-waivable, legal prohibitions.


Common law

''
Black's Law Dictionary ''Black's Law Dictionary'' is the most frequently used legal dictionary in the United States. Henry Campbell Black (1860–1927) was the author of the first two editions of the dictionary. History The first edition was published in 1891 by West P ...
'' defines the rule against perpetuities as " e common-law rule prohibiting a grant of an estate unless the interest must vest, if at all, no later than 21 years (plus a period of gestation to cover a posthumous birth) after the death of some person alive when the interest was created." At
common law In law, common law (also known as judicial precedent, judge-made law, or case law) is the body of law created by judges and similar quasi-judicial tribunals by virtue of being stated in written opinions."The common law is not a brooding omnipres ...
, the length of time was fixed at 21 years after the death of an identifiable person alive at the time the interest was created. This is often expressed as "lives in being plus twenty-one years." Under the common-law rule, one does not look to whether an interest actually will vest more than 21 years after the lives in being. Instead, if there exists any possibility at the time of the grant, however unlikely or remote, that an interest will vest outside the perpetuities period, the interest is void and is stricken from the grant. The rule does not apply to interests in the grantor himself. For example, the grant "For A so long as alcohol is not sold on the premises, then to B" would violate the rule as to B. However, the conveyance to B would be stricken, leaving "To A so long as alcohol is not sold on the premises." This would create a ''
fee simple In English law, a fee simple or fee simple absolute is an estate in land, a form of Freehold (English law), freehold ownership. A "fee" is a vested, inheritable, present possessory interest in land. A "fee simple" is real property held without l ...
determinable'' in A, with a possibility of '' reverter'' in the grantor (or the grantor's heirs). The grant to B would be void as it is possible alcohol would be sold on the premises more than 21 years after the deaths of A, B, and the grantor. However, as the rule does not apply to grantors, the possibility of reverter in the grantor (or his heirs) would be valid.


Statutory modification

Many jurisdictions have statutes that either cancel out the rule entirely or clarify it as to the period of time and persons affected: * In England and Wales, dispositions of property subject to the rule before 14 July 1964 remain subject to the rule. The
Perpetuities and Accumulations Act 1964 The Perpetuities and Accumulations Act 1964 (13 Eliz. 2c 55 is an Act of Parliament, Act of the Parliament of the United Kingdom. In English land law it reformed the rule against perpetuities. See also *Perpetuities and Accumulations Act 2009 E ...
provides for the effect of the rule of interests created thereafter. The Perpetuities and Accumulations Act 2009 codified the "wait and see" doctrine developed by courts and made the perpetuity period 125 years. * In Scotland there are similar provisions under the Trusts (Scotland) Act 1921. * In the
Republic of Ireland Ireland ( ga, Éire ), also known as the Republic of Ireland (), is a country in north-western Europe consisting of 26 of the 32 Counties of Ireland, counties of the island of Ireland. The capital and largest city is Dublin, on the eastern ...
, the rule was abolished as of 1 December 2009. * The states of the
United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country Continental United States, primarily located in North America. It consists of 50 U.S. state, states, a Washington, D.C., ...
have differing approaches. ** Some states follow the "wait-and-see approach", or "second look doctrine", and/or apply the "cy près doctrine". Under the wait-and-see approach, the validity of a suspect future interest is determined on the basis of facts as they now exist at the end of the measuring life, and not at the time the interest was created. Under the cy près doctrine, if the interest does violate the rule against perpetuities, the court may reform the grant in a way that does not violate the rule and reduce any offensive age contingency to 21 years. ** 29 states or territories have adopted the Uniform Statutory Rule Against Perpetuities (or some variant of it), which extends the waiting period typically to 90 years after creation of the interest. ** At least six states have repealed the rule in its entirety, and many have extended the vesting period of the wait-and-see approach for an extremely long period of time (in
Florida Florida is a U.S. state, state located in the Southeastern United States, Southeastern region of the United States. Florida is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia (U.S. state), Geo ...
, for example, up to 360 years for trusts). * In
Australia Australia, officially the Commonwealth of Australia, is a sovereign country comprising the mainland of the Australian continent, the island of Tasmania, and numerous smaller islands. With an area of , Australia is the largest country by ...
, each of the states has followed the UK approach to perpetuities, with
statutory A statute is a formal written enactment of a legislative A legislature is an deliberative assembly, assembly with the authority to make laws for a Polity, political entity such as a Sovereign state, country or city. They are often contraste ...
modification. In
New South Wales ) , nickname = , image_map = New South Wales in Australia.svg , map_caption = Location of New South Wales in AustraliaCoordinates: , subdivision_type = Country , subdivision_name = Australia , established_title = Before federation , es ...
, for example, the ''Perpetuities Act 1984'' limits perpetuities to 80 years,
The Perpetuities Act 1984
' (NSW) s7.
but also adopts the "wait and see" approach.


Application in the United States

The rule against perpetuities is one of the most difficult topics encountered by law school students. It is notoriously difficult to apply properly: in 1961, the
Supreme Court of California The Supreme Court of California is the Supreme court, highest and final court of appeals in the judiciary of California, courts of the U.S. state of California. It is headquartered in San Francisco at the Earl Warren Building, but it regularly h ...
ruled that it was not
legal malpractice Legal malpractice is the term for negligence Negligence (Lat. ''negligentia'') is a failure to exercise appropriate and/or ethical ruled care expected to be exercised amongst specified circumstances. The area of tort law known as ''negligence ...
for an attorney to draft a will that inadvertently violated the rule. In the
United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country Continental United States, primarily located in North America. It consists of 50 U.S. state, states, a Washington, D.C., ...
, the common law rule has been abolished by statute in Alaska, Idaho, New Jersey, Pennsylvania, Kentucky, Rhode Island and South Dakota. A new US Uniform Statutory Rule Against Perpetuities was published in 1986 that adopts the “wait-and-see approach” with a flat waiting period of 90 years in place of the rule of life in being plus 21 years. , 31 jurisdictions have adopted the new rule: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Florida, Georgia, Hawaii, Indiana, Kansas, Massachusetts, Minnesota, Montana, Nebraska, Nevada, New Jersey, New Mexico, North Carolina, North Dakota, Oregon, South Carolina, South Dakota, Tennessee, Utah, Virginia, Washington, and West Virginia, and the District of Columbia and the U.S. Virgin Islands. In 2015, the New York State Legislature considered whether or not to adopt the new rule. Other jurisdictions apply the ''cy-près'' doctrine, which validates contingent remainders and executory interests. Under certain circumstances, the traditional rule would have considered these remainders and interests to be void.


Applications

In 1919, lumber baron Wellington R. Burt died, leaving a will that specified that apart from small allowances, his estate was not to be distributed until 21 years after the death of the last of his grandchildren to be born in his lifetime. This condition was met in 2010, 21 years after his granddaughter Marion Landsill died in November 1989. After the heirs reached an agreement, the estate, which had reached an estimated value of between $100–110 million, was finally distributed in May 2011, 92 years after his death. Real estate developer Henry G. Freeman established the Henry G. Freeman Jr. Pin Money Fund, which was intended to provide an annuity of $12,000 per year to the
First Lady of the United States The first lady of the United States (FLOTUS) is the title held by the hostess of the White House, usually the wife of the president of the United States, concurrent with the president's term in office. Although the first lady's role has never ...
. Freeman died in 1917, but no presidential spouse received any payments from the fund until after Freeman's then-living descendants died out in 1989. Although Freeman's will stated that the payments were intended "to continue in force as long as this glorious government lasts", the trustees of the fund determined that maintaining the trust for more than 21 years after 1989 would violate the rule against perpetuities, and terminated the trust by agreement with then-First Lady
Michelle Obama Michelle LaVaughn Robinson Obama (born January 17, 1964) is an American attorney and author who served as First Lady of the United States, first lady of the United States from 2009 to 2017. She was the first African-American woman to serve i ...
in 2010 to give the fund to charity instead. Hence, only four First Ladies ever received payments from the fund.


Charity-to-charity exception

The rule never applies to conditions placed on a conveyance to a charity that, if violated, would convey the property to another charity. For example, a conveyance "to the
Red Cross The International Red Cross and Red Crescent Movement is a Humanitarianism, humanitarian movement with approximately 97 million Volunteering, volunteers, members and staff worldwide. It was founded to protect human life and health, to ensure re ...
, so long as it operates an office on the property, but if it does not, then to the
World Wildlife Fund The World Wide Fund for Nature Inc. (WWF) is an international non-governmental organization founded in 1961 that works in the field of wilderness preservation and the reduction of human impact on the environment. It was formerly named the W ...
" would be valid under the rule, because both parties are charities. Even though the interest of the fund might not vest for hundreds of years, the conveyance would nonetheless be held valid. The exception, however, does not apply if the conveyance, upon violation of the condition, is not from one charity to another charity. Thus, a devise "to John Smith, so long as no one operates a liquor store on the premises, but if someone does operate a liquor store on the premises, then to the Roman Catholic Church" would violate the rule. The exception would not apply to the transfer from John Smith to the Roman Catholic Church because John Smith is not a charity. Also, if the original conveyance was "to John Smith and his heirs for as long as John Smith or his heirs do not use the premises to sell liquor, but if he does, then to the Red Cross" this would violate the rule because it could be more than 21 years before the interest in Red Cross would vest, and therefore, their interest is void. Thus leaving John with a fee simple determinable and the grantor a possibility of reverter. A famous actual example of this exception applies to Harvard's
Widener Library The Harry Elkins Widener Memorial Library, housing some 3.5million books in its "vast and cavernous" stacks (library architecture), stacks, is the centerpiece of the Harvard College Libraries (the libraries of Harvard's Harvard Faculty of Arts an ...
.
Eleanor Elkins Widener Eleanor Elkins Widener ( Elkins, later known as Eleanor Elkins Widener Rice or Mrs. Alexander Hamilton Rice; 1937) was an American heiress, socialite, philanthropist, and adventuress best remembered for her donation to Harvard University ...
, the library's benefactor, stipulated that no “additions or alterations” could be made to the façade of the building. If the university ever changes the façade, it loses the building to the
Boston Public Library The Boston Public Library is a municipal public library system in Boston, Massachusetts, United States, founded in 1848. The Boston Public Library is also the Library for the Commonwealth (formerly ''library of last recourse'') of the Commonweal ...
. Because both Harvard and the Boston Public Library are charities, the restriction can apply indefinitely.


Saving clause

In order to satisfy the rule against perpetuities, the class of people must be limited and determinable. Thus, one cannot say in a deed "until the last of the people in the world now living dies, plus 21 years." To avoid problems caused by incorrectly drafted legal instruments, practitioners in some jurisdictions include a "saving clause" almost universally as a form of
disclaimer A disclaimer is generally any statement intended to specify or delimit the scope of rights and obligations that may be exercised and enforced by parties in a legally recognized relationship. In contrast to other terms for legally operative langua ...
. This standard clause is commonly called the "Kennedy clause" or the "Rockefeller clause" because the determinable "lives in being" are designated as the descendants of Joseph P. Kennedy (the father of
John F. Kennedy John Fitzgerald Kennedy (May 29, 1917 – November 22, 1963), often referred to by his initials JFK and the nickname Jack, was an American politician who served as the 35th president of the United States from 1961 until assassination of Joh ...
), or John D. Rockefeller. Both designate well-known families with many descendants, and are consequently suitable for named, identifiable lives in being. For a time, it was popular to use a
Royal lives clause A Royal lives clause is a contract clause which provides that a certain right must be exercised within (usually) the lifetime plus 21 years of the last living descendant of a British Monarch who happens to be alive at the time when the contract is m ...
, and make the term of a deed run until the last of the descendants of (for example)
Queen Victoria Victoria (Alexandrina Victoria; 24 May 1819 – 22 January 1901) was Queen of the United Kingdom of Great Britain and Ireland from 20 June 1837 until Death and state funeral of Queen Victoria, her death in 1901. Her reign of 63 years and 21 ...
now living dies plus 21 years.


Related rules

Jurisdictions may limit
usufruct Usufruct () is a limited ius in re, real right (or ''in rem'' right) found in Civil law (legal system), civil-law and mixed jurisdictions that unites the two property interests of ''usus'' and ''fructus'': * ''Usus'' (''use'') is the right to use ...
periods. For example, if a corporation builds a ski slope, and gives rights of use (usufruct) as gifts to corporate partners, these cannot last in perpetuity, but must terminate after a period that must be specified, e.g. 10 years. A perpetual usufruct is thus forbidden and "perpetual" might mean a long, but finite period, such as 99 years. Here usufruct is distinct from a share, which may be held in perpetuity.


Illustrations

The fertile octogenarian and the unborn widow are two
legal fiction A legal fiction is a question of law, fact assumed or created by courts, which is then used in order to help reach a decision or to apply a legal rule. The concept is used almost exclusively in common law jurisdictions, particularly in England a ...
s from the
law Law is a set of rules that are created and are law enforcement, enforceable by social or governmental institutions to regulate behavior,Robertson, ''Crimes against humanity'', 90. with its precise definition a matter of longstanding debate. ...
of
real property In English common law, real property, real estate, immovable property or, solely in the US and Canada, realty, is land which is the property of some person and all structures (also called Land improvement, improvements or Fixture (property ...
(and
trusts A trust is a legal relationship in which the holder of a right gives it to another person or entity who must keep and use it solely for another's benefit. In the Anglo-American common law In law, common law (also known as judicial precedent, ...
) that can be used either to invoke the
rule against perpetuities The rule against perpetuities is a legal rule in the Common law, American common law that prevents people from using legal instruments (usually a deed or a will and testament, will) to exert control over the ownership of private property for a ti ...
to make an interest in property void or, alternatively and much more frequently, to demonstrate the seemingly bizarre results that can occur as a result of the rule. The rule itself, simply stated, makes a future interest in property void if it can be logically proven that there is some possibility of the interest not vesting or failing within 21 years after the end of a life in being at the time the interest is created.


The fertile octogenarian

The fertile octogenarian is a fictitious character that comes up when applying the rule against perpetuities. The rule presumes that anyone, even an octogenarian (i.e., someone between 80 and 90 years of age) can parent a child, regardless of sex or health. For instance, suppose that a
will Will may refer to: Common meanings * Will and testament A will or testament is a legal document that expresses a person's (testator) wishes as to how their property (estate (law), estate) is to be distributed after their death and as to which ...
devises a piece of land known as
Blackacre Blackacre, Whiteacre, Greenacre, Brownacre, and variations are the placeholder names used for fictitious estate (law), estates in land. The names are used by professors of law in common law jurisdictions, particularly in the area of real property ...
"to A for her life, and then to the first of A's children to reach 25 years of age." A is, at the time the will is
probate Probate is the judicial process whereby a will is "proved" in a court of law and accepted as a valid public document that is the true last testament of the deceased, or whereby the estate is settled according to the laws of intestacy in the sta ...
d, an 85-year-old woman. In applying the rule against perpetuities, an imaginative lawyer will argue (and a court must accept under the
common law In law, common law (also known as judicial precedent, judge-made law, or case law) is the body of law created by judges and similar quasi-judicial tribunals by virtue of being stated in written opinions."The common law is not a brooding omnipres ...
rule itself) that A could have a child in her 86th year and then in her 87th year all of A's other children could die, then in her 88th year A herself could die. Because the interest will not vest until her new child reaches 25 years of age, which cannot happen until more than 21 years after A and her other children (together who form the "lives in being" to which the rule refers) have all died, the rule against perpetuities makes the entire gift "to the first of A's children to reach 25 years of age" void. A will hold Blackacre for life, and then the property will revert to the person whose will transferred it to A in the first place. (Actually, it will go to that person's estate, since the will was probated only after his death.) While it is true that there is often no statutory maximum age limit to perform an adoption, and adopted children are often treated the same as natural children, so an 86-year-old woman who adopts a newborn child is legally in the same position as an 86-year-old woman who gives birth, the fertile octogenarian rule predates the laws allowing legal adoption. The
legal fiction A legal fiction is a question of law, fact assumed or created by courts, which is then used in order to help reach a decision or to apply a legal rule. The concept is used almost exclusively in common law jurisdictions, particularly in England a ...
of the fertile octogenarian assumes that a living person, regardless of sex, age, or physical condition, will always be capable of having more children, thus allowing an interest to vest 21 years after all the lives in being at the time of the grant are dead. Couples have been known to marry in their late eighties. In certain places this assumption will be limited to a fixed age set by statute. Furthermore, many jurisdictions have discarded old common-law fictions such as the "fertile octogenarian." A related legal fiction, which assumes that a living person is fertile at birth, is known as the precocious toddler.


The unborn widow

The problem of the unborn widow is a frequently used illustration of the odd outcomes of the traditional rule against perpetuities. The unborn widow rule prohibits an unidentified widow from being treated as a validating life. If, for example, a grantor's will devised land "to my son, for life; then to his wife r widow for life; then to his children living at the time of her death," the children's contingent remainder (contingent on their status as "living" at the time of the widow's death) would be invalid, even if the grantor's son was an elderly and already-married man. Regardless of the age of the grantor's son, he could leave or lose by death his current wife and subsequently marry another woman who was not yet born at the time of conveyance; thus the widow that survived him would not be, with certainty, a life in being at the time of conveyance.


Other examples

Other hypothetically relevant possibilities which almost never actually occur but have been invoked by lawyers or courts to invalidate transfers under the rule against perpetuities include the slothful executor (a situation where the executor of the estate does not probate the will for many years after the testator's death), the magic gravel pit (a transfer to be made as soon as a gravel pit is out of gravel may not vest for hundreds of years), the war that never ends (a transfer to be made at the end of a war might never happen), and other similar situations.


Criticism and humor

Because these hypothetical scenarios show how a reasonable gift can be voided based on so unlikely an outcome, they have generated much criticism among legal scholars, resulting in the abrogation of the rule against perpetuities by
statute A statute is a formal written enactment of a legislature, legislative authority that governs the legal entities of a city, State (polity), state, or country by way of consent. Typically, statutes command or prohibit something, or declare Public p ...
in many jurisdictions. Many
U.S. state In the United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country Continental United States, primarily located in North America. It consists of 50 U.S. state, ...
s have adopted laws mollifying the application of the rule by requiring courts to "wait and see" for a period of years, sometimes as long as 360 years (which effectively negates the possibility of litigation ensuing during the life of any person alive at the same time of the author of the will). Some jurisdictions have ameliorated specific problems of the rule by creating statutory presumptions to counter those problems. Under such statutes, for example, a woman is presumed to no longer be fertile after a particular age (typically 55), and a gift to a person's widow or widower is presumed to vest in whoever was that person's spouse at the time of the gift. These rules have also long been a target of legal
humorist A humorist ( American) or humourist ( British spelling) is an intellectual who uses humor Humour ( Commonwealth English) or humor (American English American English, sometimes called United States English or U.S. English, is the se ...
s.


Cultural references

The rule against perpetuities figures as a prominent plot point in the 1981 film ''
Body Heat Thermoregulation is the ability of an organism to keep its body temperature within certain boundaries, even when the surrounding temperature is very different. A thermoconforming organism, by contrast, simply adopts the surrounding temperature ...
''. It also figured as a secondary plot line in the 2011 film ''
The Descendants ''The Descendants'' is a 2011 American comedy-drama film directed by Alexander Payne. The screenplay by Payne, Nat Faxon, and Jim Rash is based on the The Descendants (novel), 2007 novel of the same name by Kaui Hart Hemmings. The film stars Ge ...
''.


See also

* Cestui que *
Cy-près doctrine The cy-près doctrine ( ; Law French Law French ( nrf, Louai Français, enm, Lawe Frensch) is an archaic language originally based on Old Norman Old Norman, also called Old Northern French or Old Norman French ( fro, Ancien Normant, nr ...
*
Executory contract An executory contract is a contract A contract is a legally enforceable agreement between two or more Party (law), parties that creates, defines, and governs mutual rights and obligations between them. A contract typically involves the transfe ...
* Executory interest *
Royal lives clause A Royal lives clause is a contract clause which provides that a certain right must be exercised within (usually) the lifetime plus 21 years of the last living descendant of a British Monarch who happens to be alive at the time when the contract is m ...
*
Statutes of Mortmain The Statutes of Mortmain were two enactments, in 1279 and 1290, passed in the reign of Edward I of England Edward I (17/18 June 1239 – 7 July 1307), also known as Edward Longshanks and the Hammer of the Scots, was King of England an ...
* '' Thellusson v Woodford'' * '' Werling v. Sandy'' (Ohio 1985)


References


External links

* * {{DEFAULTSORT:Rule Against Perpetuities Property law Equity (law) Wills and trusts Common law rules