Adams v. Link
1958 Conn. LEXIS 236, 145 A.2d 753, 145 Conn. 634 (1958)
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Rule of Law:
A testamentary trust may not be terminated, even with the consent of all beneficiaries, if a material purpose of the settlor remains to be accomplished. The court's duty is to enforce the testator's intent, not to remake the trust instrument to suit the beneficiaries' preferences.
Facts:
- Mildred A. Kingsmill's will established a trust with the residue of her estate.
- The trust directed trustees to pay the net income for life to Mayes M. Foeppel.
- Upon Foeppel's death, the trust was to terminate, and the remaining principal was to be distributed to The New York Association for the Blind.
- Kingsmill's heirs at law, who were not beneficiaries of the trust, contested the validity of her will.
- To resolve the will contest, the heirs, Foeppel (the life beneficiary), and The New York Association for the Blind (the remainder beneficiary) entered into a compromise agreement.
- The agreement stipulated that the will contest would be dropped, the trust would be terminated, and the assets would be distributed outright among the parties.
- The executors and trustees selected by Kingsmill refused to participate in or carry out the agreement.
Procedural Posture:
- Two of Mildred A. Kingsmill's heirs at law filed an appeal from the admission of her will to probate.
- During the appeal, the parties created a compromise agreement that was made expressly subject to court approval.
- The plaintiffs (all parties to the agreement except the charity) filed an action in the Superior Court (a trial court) seeking approval of the agreement and an order compelling the defendant executors and trustees to carry it out.
- The Superior Court refused to approve the agreement.
- The plaintiffs appealed the Superior Court's decision to the Supreme Court of Errors of Connecticut, the state's highest court.
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Issue:
May a testamentary trust be terminated by a compromise agreement among all beneficiaries and heirs if a material purpose of the trust's creator has not yet been accomplished?
Opinions:
Majority - King, J.
No. A testamentary trust may not be terminated by an agreement of all beneficiaries if a material purpose of the trust's creator remains unfulfilled. The court's primary function is to protect the testator's intent. Kingsmill's obvious objectives were to provide an assured, managed income for Foeppel's entire life and to preserve an intact corpus for the charity upon Foeppel's death. Terminating the trust and giving Foeppel an outright sum would defeat the material purpose of providing her with the protection of a professionally managed, lifelong income stream. The fact that the agreement was part of a will contest settlement does not alter this principle, as the court will not approve an agreement that drastically changes the provisions of a will and abolishes a trust contrary to established legal rules.
Analysis:
This decision reaffirms the Claflin doctrine, prioritizing the material purpose of the settlor over the unanimous wishes of the beneficiaries. It clarifies that the desire to settle a will contest is not, by itself, a sufficient reason to override a testator's clearly expressed intent to create a trust with protective features, such as providing a managed, lifelong income stream. The ruling strengthens the position of trustees who seek to uphold the terms of a trust against beneficiaries' attempts at premature termination, ensuring that the settlor's objectives are honored as long as they are lawful and possible to achieve.
