American Security & Trust Co. v. Cramer
United States District Court for the District of Columbia
175 F. Supp. 367 (D.D.C. 1959)
Abraham Hazen's will left a trust remainder to be divided among his daughter Hannah's children for life, then to each child's own heirs under intestacy law upon that child's death; two of Hannah's children (Depue and Horace) were born after Abraham's death, making their remainder interests void under the rule against perpetuities, while two others (Mary and Hugh) were alive when the interest was created.
Whether, where a will provides for a remainder to pass to the heirs of each individual life beneficiary as they die, rather than to a subsequent generation as a single class, and the interests of some beneficiaries are void, the entire gift over is void as a class gift.