Gruen v. Gruen
New York Court of Appeals
496 N.E.2d 869 (1986)
Victor Gruen wrote his son Michael (plaintiff) letters stating his intent to give Michael a valuable painting for his 21st birthday, while Victor kept physical possession and a life estate in the artwork. Michael told friends and associates about the gift and kept both letters for over 17 years, planning to use them to prove the gift after his father died. After Victor's death, his widow, Ms. Gruen (defendant), refused to turn over the painting, and Michael sued; the trial court found the retained life estate invalidated the gift, but the Appellate Division held a gift can be valid even with a retained life estate, and Ms. Gruen sought further review.
Whether a valid inter vivos gift requires the donor's intent to make a present transfer, actual or constructive delivery, and acceptance by the donee.