First National Bank of Chicago v. King

Louis Swift's will created a trust paying his daughter-in-law Lydia Niblack Swift, with the remainder to pass in equal shares per stirpes to the 'lawful descendants' of his son Alden and Niblack if Niblack died before the trust ended. Alden and Niblack had three children: Lydia, Nathan, and Narcissa. Nathan predeceased Niblack, leaving a biological son (Nathan Jr.) and an adopted daughter, Martha (defendant). After Niblack died, trust proceeds went to Lydia, Narcissa, and Nathan Jr., but the trustee, First National Bank of Chicago (plaintiff), refused to pay Martha, reasoning that as an adopted child she wasn't a 'lawful descendant.' The trustee sought a declaratory judgment on the issue; the circuit court sided with the trustee, and the appellate court reversed.