## Facts

- A testator left the residue of his personal estate in trust to be sold and the proceeds divided: one-third to his wife, one-third to one son, and one-third to his son Adelbert.
- Adelbert’s one-third share was to be distributed in installments: $10,000 at age 21, $10,000 at age 25, and the balance at age 30.
- Adelbert reached age 21 and received the first $10,000 installment.
- Before turning 25, Adelbert filed a bill in equity seeking immediate payment of the remaining trust principal, arguing the postponement provisions after age 21 were void.
- Adelbert’s beneficial interest in his share was vested and absolute, and no other person had any beneficial interest in that share.
- A single justice dismissed the bill; Adelbert appealed to the full court.

## Issues

1. Whether a beneficiary with a vested, absolute, and sole beneficial interest may compel trustees to terminate a trust and distribute principal immediately, despite will provisions postponing payment to later ages.
2. Whether age-based postponements of distribution in a testamentary trust are invalid as unlawful restraints or as contrary to public policy.

## Decision

- The Supreme Judicial Court of Massachusetts affirmed the decree dismissing the beneficiary’s bill.
- The court held the will’s staged distribution provisions (at ages 21, 25, and 30) were valid and enforceable.
- The beneficiary could not compel acceleration of distribution because doing so would defeat the testator’s intended plan for the trust.

## Legal Principles

- A settlor/testator may impose restrictions and limitations on the timing of a beneficiary’s enjoyment that are not contrary to law or public policy.
- Even when a beneficiary’s interest is vested and absolute, courts will not terminate or modify a trust at the beneficiary’s request if termination would defeat a material purpose of the trust.
- A trust is not treated as “dry” where trustees retain active duties, including holding and managing the property and making distributions only at specified times.
- Postponing distribution to a living beneficiary’s specified ages, within permissible limits, does not by itself violate public policy or rules limiting permissible durations.

## Conclusion

The court enforced the testator’s age-staggered distribution plan and refused to terminate the trust early, establishing that beneficiary preference for immediate possession does not override a lawful material purpose expressed in the trust’s terms.


Claflin v. Claflin, 149 Mass. 19, 20 N.E. 454 (Mass. 1889)