Laughlin v. Elliott
Kentucky Supreme Court
259 S.W. 1031 (1924)
After Anna Baker's divorce from Laughlin and remarriage to J.H. Baker, the Bakers conveyed property by deed to their daughter Nannie Neeley, reserving Anna a life estate followed by a life estate for Neeley upon Anna's death, with the property then passing to Anna's grandchildren in equal portions upon Neeley's death; at the time of the deed, Anna also had three sons. After Anna's death, litigation arose to determine the parties' interests under the deed, and the trial court held the grandchildren provision void under the rule against perpetuities, leaving none of the litigating parties with any interest in the property.
Whether a future interest in property that may not vest within 21 years after the life of a person who was living when the interest was created is void.