The Trustees of Amherst College, Respondents v. Thomas G. Ritch

Summary

The New York Court of Appeals affirmed the lower courts, holding that (1) facts found by the trial court are presumed when the decision lacks specific findings, (2) a secret trust was created by the testator’s promise to the residuary legatees, (3) that trust is not void as an evasion of the 1860 charitable‑gift limitation because the widow and next of kin waived their statutory rights by releases, and (4) the releases are pure releases, not transfers, thereby extinguishing the statutory claim. Justice Andrews dissented, arguing the trust violated the statute.