Dickson v. Alexandria Hospital

Facts

In 1907, George Simpson died and was survived by his wife, Virginia Simpson, and their two sons, George Robbins Simpson (Robbins) and French Simpson. In his will, George gave their family home to his wife, $10,000 to each of his sons when they reached 25 years of age, and the remainder of his property to his wife unless she remarried. Upon the event that Virginia remarried, the remainder of George’s estate was to be divided equally between his sons. Robbins died unmarried and without a will in 1934. French died in 1940, leaving a will providing his entire estate to his widow, Paulette Dickson (plaintiff). Virginia died in 1944 without having remarried. Virginia’s will made several specific requests, established a trust fund, and left her entire residuary estate to Alexandria Hospital, Inc. (defendant) after the termination of the trust. Dickson filed suit, alleging that George’s will created a defeasible life estate in Virginia, one-half of which passed to Dickson upon the death of French as his only heir. The district court dismissed the complaint, finding that George’s will provided Virginia with a defeasible fee-simple estate, which became absolute when Virginia died without having remarried. Dickson appealed.