Iglehart v. Iglehart

Background

A woman who lived in the District of Columbia left a will that created trusts to pay for the perpetual maintenance of cemetery lots and monuments. The will named a New York cemetery corporation to receive and apply money for upkeep. Opponents argued a D.C. law that limits long-term future interests (the rule against perpetuities) and a separate D.C. statute meant only domestic cemetery corporations could hold such trusts, so the gifts were invalid.

Reasoning

The Court examined two D.C. statutes: one that permits cemetery associations to take gifts for perpetual maintenance, and another that limits future estates. The Justices read the statutes together and concluded they can be harmonized so the special cemetery statute operates. The Court also relied on the long-standing principle of comity between states, holding that if D.C. permits these trusts and New York law also allows them, a New York cemetery corporation may hold and administer the funds for maintenance. The Court found the will’s first and twelfth clauses valid and rejected arguments that the tenth clause or a conversion-to-personalty claim defeated the trusts.

Real world impact

The decision lets owners in D.C. leave money for perpetual upkeep of graves and monuments to out-of-state cemetery corporations when both jurisdictions permit such trusts. The judgment was affirmed and costs were charged against the appellants; the executor may seek a reasonable allowance from the fund.