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In re Davidson’s Will, 223 Minn. 268, 26 N.W.2d 223, 170 A.L.R. 215

Facts

Alfred Rolland Davidson died leaving a will that established a trust for his daughter, Lynn Elizabeth Davidson, which specified that she would receive the trust assets upon reaching the age of majority. At the time of his death, Minnesota law stated that females reached majority at 18, but this law was amended after his death to set the age at 21. Lynn turned 18 on May 26, 1944, but the court ruled that she would not reach majority until May 26, 1947, based on the amended law.

The decedent, Alfred Rolland Davidson, whose legal domicile was Minnesota, died in California on April 14, 1929, and left surviving him a daughter, Lynn Elizabeth Davidson, born May 26, 1926.

Issue

Did Lynn Elizabeth Davidson reach the age of majority under her father's will when she turned 18, or does the amended law requiring her to be 21 apply?

Edward L. Boyle, as guardian, appeals from a judgment determining that his ward, Lynn Elizabeth Davidson, will not reach the age of majority, as defined in her father's last will and testament, until she attains the age of 21 years.

Rule

The court held that the term 'majority' in the will referred to a status rather than a fixed age, and that the legislature has the power to change the age of majority.

A person who has reached his majority has thereby arrived at the status or condition of full age whereby he is entitled, at law, to the management of his own affairs and to the enjoyment of civic rights.

Analysis

The court analyzed the language of the will and determined that the testator intended for the trust to remain in effect until Lynn reached a legal status of majority, which was interpreted in light of the law at the time of the will's execution. The court emphasized that the testator's intent was to protect Lynn until she could manage her own affairs, and that the change in law did not impair any vested rights since none had accrued under the previous statute.

The will here provides that if the daughter dies before reaching her majority without leaving lawful issue the entire trust estate shall be conveyed to the trustee personally, free and clear of the trust.

Conclusion

The court affirmed the judgment that Lynn would not reach the age of majority until she turned 21, thus upholding the continuation of the trust until that time.

The judgment is affirmed.

Who won?

Stephen R. Kirby, the trustee, prevailed because the court upheld the interpretation of the will that required Lynn to reach the age of 21 before receiving the trust assets.

The trial court found and adjudged that the daughter did not, when she was 18 years old, reach the age of majority within the intent of her father's will; that she would not reach such majority until the age of 21 years.

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