## Facts

- Florence B. Lyon died owning four horses and six dogs and left an estate of about $1.4 million.
- Her will directed that a substantial portion of the estate be used for the care of those animals.
- The will further directed that, after the animals’ deaths, remaining funds would pass to Princeton University for scholarship and other uses.
- The executors and Princeton University petitioned the Orphans’ Court for declaratory judgment on the validity and administration of the animal-care provision.
- Estimated animal-care needs were modest relative to the amount set aside (including land, a shelter, and ongoing annual maintenance).
- The petition sought a determination of (i) whether the animal-care provision created an enforceable arrangement, (ii) what amount was reasonably necessary for the animals, and (iii) when any excess should be distributed to Princeton.

## Issues

1. Whether a testamentary direction to devote estate property to the care of specified animals, with a charitable remainder, creates a valid trust rather than an unenforceable honorary arrangement.
2. If valid, whether the court may limit or reform the funding level when the amount designated for animal care substantially exceeds what is reasonably necessary to carry out the decedent’s intent.
3. Whether the charitable remainderman must wait until the animals’ deaths to receive any distributions, or whether excess can be distributed earlier and the arrangement limited in duration.

## Decision

- The court construed the will as creating a valid trust for animal care with an enforceable remainder in favor of Princeton University.
- The court reformed the arrangement to reflect the decedent’s intent to provide reasonable animal care without immobilizing a disproportionate share of the estate.
- The court limited the animal-care component’s duration to no more than 21 years after the decedent’s death.
- The court capped the amount of principal that could be held for animal care at approximately $125,000–$150,000 as reasonably necessary.
- The court permitted distribution to Princeton of funds exceeding the reasonable animal-care amount before the animals’ deaths, while retaining sufficient funds to provide for the animals.

## Legal Principles

- A testamentary provision directing property to be used for the care of specific animals, coupled with a human or charitable remainder interest, may be enforced as a trust.
- A court may reform or limit a testamentary trust when literal execution would defeat the testator’s intent by allocating property far beyond what is reasonably necessary for the trust purpose.
- Courts may constrain duration and administration of such trusts to avoid impermissible or wasteful restraints on property, including by applying a 21-year outer limit consistent with perpetuities policy.
- Where the trust purpose can be satisfied with a reasonable fund, surplus may be accelerated to the remainderman while preserving adequate resources to carry out the primary purpose.

## Conclusion

The Orphans’ Court enforced the animal-care provision as a trust but curtailed both its duration and funding to a reasonable level and allowed early transfer of excess assets to the charitable remainderman, thereby implementing animal care while preventing disproportionate sequestration of estate property.


In re Lyon’s Est., 67 Pa. D. & C.2d 474 (Pa. Ct. Com. Pl. Orphans’ Ct. Div. 1974)