Uchtorff v. Hanson

Alfred's will placed trust income for wife Pearl during her lifetime, with the remainder going to son Richard "as an indefeasibly vested interest in fee" if Richard survived Alfred, or otherwise to Richard's children; Richard survived Alfred but predeceased Pearl, and his will left his estate to his later wife Christa (plaintiff), who claimed Richard's remainder interest vested at Alfred's death and passed to her, while Richard's children (defendants) argued the interest never vested because Richard didn't survive Pearl, and the district court ruled for the children.

Whether, if a testator grants a life estate with the remainder to a beneficiary conditioned on surviving the testator, the beneficiary's remainder interest vests upon the testator's death.