Fitzpatrick v. Mercantile-Safe Deposit & Trust Co.

This appeal is the natural sequel to Hawkins v. Ghent, 154 Md. 261, 140 A. 212, wherein it was held that the primary life estates created under the will of Amanda M. Hawkins *538were not violative of the rule against perpetuities (Rule) and, therefore, valid; but the question of the validity of the subsequent limitations—all being contingent—was left open.

In 1876, John W. Hawkins and Amanda Hawkins, his wife, conveyed certain real and personal property to Augustine James Dalrymple in trust for Amanda Hawkins, one of the grantors, during her life. The deed of trust, among other things, directed…