Baker v. Weedon

John Weedon's will left his farm to his second wife Anna (plaintiff) for life, then to her children, or, if she had none, to his grandchildren from his first marriage (the Bakers, defendants); Anna had no children, so the Bakers held a future interest that would vest upon her death. As Anna aged, her declining health and reliance on modest farm income made it hard for her to cover expenses and taxes, even as the land's value soared due to nearby urban development -- worth $168,500 at the time but projected to nearly double within four years. Anna sued in chancery court to force an immediate sale so she could use the proceeds to support herself, and the chancellor ordered the sale based on a theory of economic waste; the Bakers appealed, arguing the farm wasn't deteriorating and rental income covered its taxes, so a sale was unwarranted.

Whether an equity court may order a judicial sale of land subject to a future interest only where the property is deteriorating or otherwise being wasted, or whether it may also weigh the sale's overall impact on the best interests of both the life tenant and the future interest holders.