In re Estate of Evans
Supreme Court of Pennsylvania
356 A.2d 778 (1976)
About a month before his death, Arthur Evans gave Vivian Kellow (plaintiff), who had been caring for him, the keys to his safe-deposit box and told her its contents were hers, a statement he repeated to others; Kellow told others the same thing and showed people the keys, which she kept under her mattress, but the box itself remained registered in Evans's name throughout. Upon Evans's death, Kellow surrendered the keys to the bank while claiming the contents belonged to her; the lower court found no valid inter vivos gift had occurred and included the box's contents in Evans's estate, and Kellow appealed.
Whether giving someone the keys to a safe-deposit box and telling them its contents are theirs completes a valid inter vivos gift, when the box remains registered in the donor's own name and the donor never otherwise divests himself of control over its contents.