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Jewish National Fund, Council of Israel, Hadassah-Miami Beach Chapter v. Reinman

Citations: 546 So. 2d 1165; 14 Fla. L. Weekly 1809; 1989 Fla. App. LEXIS 4344Docket: No. 89-496

Court: District Court of Appeal of Florida; August 1, 1989; Florida; State Appellate Court

Narrative Opinion Summary

An appeal challenged a final summary judgment regarding a bequest in a testator's will. The court affirmed that the bequest to a beneficiary did not lapse, allowing the beneficiary to inherit despite not being located by the estate's personal representative within one year of the testator's death. The decision was based on two key points: the will explicitly bequeathed 50% of the estate to the beneficiary, and the use of precatory language ("I request") did not establish a condition precedent for the bequest contingent upon locating the beneficiary within the specified timeframe. The ruling referenced relevant case law to support this interpretation.

Legal Issues Addressed

Explicit Bequest in Will

Application: The court upheld the explicit bequest of 50% of the estate to the beneficiary, reinforcing that clear testamentary provisions take precedence.

Reasoning: The will explicitly bequeathed 50% of the estate to the beneficiary.

Interpretation of Precatory Language in Wills

Application: The usage of precatory language, such as 'I request', was found insufficient to impose a condition precedent on the bequest, permitting the beneficiary to inherit regardless of being located.

Reasoning: The use of precatory language ('I request') did not establish a condition precedent for the bequest contingent upon locating the beneficiary within the specified timeframe.

Non-Lapse of Bequest

Application: The court determined that a bequest to a beneficiary did not lapse despite the beneficiary not being located within one year of the testator's death.

Reasoning: The court affirmed that the bequest to a beneficiary did not lapse, allowing the beneficiary to inherit despite not being located by the estate's personal representative within one year of the testator's death.