Sturgis v. Sturgis, 164 N.Y. 485 (1900)
A charitable trust, valid under the laws of the relevant jurisdiction, will be enforced if the testator designates competent trustees, even if those trustees are identified by their official titles rather than their individual names.
Summary
This case concerns the validity of a charitable trust established in a will. The testatrix bequeathed funds to the selectmen of a specific parish in her hometown, to be used for the benefit of the poor in that parish. The lower courts found the trust invalid because the designated trustees were not competent to act. The New York Court of Appeals reversed, holding that the testatrix had indeed designated competent trustees by their official titles, and because the trust was valid under Massachusetts law, it should be enforced. The court emphasized that designating trustees by their official titles is equivalent to naming them individually and ensures a continuous line of successors.
Facts
Catharine Sturgis bequeathed $6,000 in her will to the selectmen (or other municipal authorities) of the East Parish of Barnstable, Massachusetts. The funds were to be held in trust and the interest used to benefit respectable persons in reduced circumstances within that parish. The will stipulated that beneficiaries should be native-born U.S. citizens or their descendants, but not dependent on the town for support. Sturgis died in 1881, and her sister received the income from this bequest until her death in 1896.
Procedural History
The Surrogate’s Court ruled that the bequest was void, finding no competent trustee designated in the will. The Appellate Division affirmed this ruling, with a divided court, based on the Surrogate’s opinion. The case was then appealed to the New York Court of Appeals.
Issue(s)
Whether the testatrix, Catharine Sturgis, successfully designated competent trustees to administer the charitable trust created in her will, given that she identified the trustees by their official titles (selectmen of the East Parish) rather than their individual names.
Holding
Yes, because designating trustees by their official character is equivalent to naming them by their proper names, as it provides a clear and continuous line of succession for administering the trust, and the trust itself is valid under Massachusetts law.
Court’s Reasoning
The Court of Appeals reasoned that the testatrix’s method of selecting trustees was practical and effective under the circumstances. By using the official description of the selectmen, she ensured a continuous line of successors to administer the trust. The court emphasized that this was not a gift to the town of Barnstable, but rather the appointment of private citizens (holding official positions) to act as trustees. The court drew an analogy to Inglis v. Trustees of the Sailors’ Snug Harbor, 3 Peters, 99, where the Supreme Court upheld a devise to trustees designated by their official titles. Quoting Inglis, the court stated: “The designation of the trustees, by their official character, is equivalent to naming them by their proper names…The trust was not to be executed by them in their official character, but in their private and individual capacities.” The court concluded that since the trust was valid under Massachusetts law and the testatrix had designated competent trustees, the funds should be paid over to those trustees. The court found no legal impediment to the selectmen acting in their individual capacities as trustees while holding their official positions, as their local knowledge would aid them in fulfilling their duties. The order of the Appellate Division and the surrogate’s decree were reversed, and the case was remanded to the Surrogate’s Court to modify the decree to direct the executor to surrender the fund to the selectmen as trustees.