Dickerson v. Union National Bank
Arkansas Supreme Court
595 S.W.2d 677 (1980)
Nina Dickerson's trust was to continue until her two sons and one son's yet-unidentified future widow had all died and the youngest grandchild reached 25, but because that widow could theoretically be someone not yet born at Nina's death, the widow's own death — potentially decades after both sons died — could be the event triggering vesting; Cecil (plaintiff) sued the trustee bank (defendant), arguing this structure violated the rule against perpetuities, and the lower court rejected his argument.
Whether, if there is any possibility at all that an interest in an estate will not vest within a period measured by lives in being at the time of testator's death plus 21 years, the interest is void under the rule against perpetuities.