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Haskell v. Staples Case Brief

Summary of Haskell v. Staples, 116 Me. 103, 100 A. 148 (1917)

Facts: Mr. McLellan died testate and Mr. Staples was appointed executor. He in turn converted all the assets into cash, paid the indebtedness and bequests, deposited the remaining cash into a bank.  Thirty years later he was determined to be of unsound mind and removed as executor.  The Pl Haskell, was then appointed.  The will provided that Mr. Staples would receive $500 and “the residue of my personal estate” left “in trust.”

Issue: Does the remaining money in the accounts belong to Mr. Staples personally, was it given in trust, and has that trust failed thereby enabling the executor to distribute that property to the heirs of the deceased?

Holding: Mr. Staples is not entitled to the residue of the personal estate, there is a resulting trust in favor of the heirs at law and the balance, after costs, should be divided among them.

Procedure: Supreme Ct decree directing will to be construed as a trust.

Rule: When other and separate provisions have been made of the legatee that indicates an intention by the testator not to bequeath the beneficial interest in other property, the legal title is also given to the legatee.  An attempted trust must fail for uncertainty and indefiniteness.

Rationale: The words “I leave in trust” coupled with “to be distributed and disposed of as he pleases” leaves no doubt that the testator intended to create a trust and not grant absolute ownership.  A trust to objects that are not charitable or undefined people, is too indefinite.  The trust is therefore void. The bequest in this will is not a charitable trust. It is as uncertain and vague as the case law cited.  When a bequest is made in terms clearly manifesting an intention that it shall be taken in trust, and the trust is uncertain or indefinite, the legatee takes the legal title only, and a trust results by implication of law to the testator’s residuary legatees or next of kin.




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