Madeleine DeClercq v. JPMorgan Chase Bank, N.A.

OPINION

RONALD LEE GILMAN, Circuit Judge.

This case requires us to decide what being someone’s “issue” means. If one’s “issue” includes all blood relatives, then Madeleine DeClercq stands to inherit about five million dollars. Michigan law, unfortunately, limits one’s “issue” to lineal descendants. For this reason, we AFFIRM the judgment of the district court.

I. BACKGROUND

Joan Bookmyer created a trust in 1992 (the Trust). According to the Trust agreement, whatever remained of the Trust at the time of her death was to be transferred to her daughter “or any other issue.” If Bookmyer had no living…