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United States Nat'l Bank v. Snodgrass - 202 Or. 530, 275 P.2d 860 (1954)

Rule:

Conditions and limitations in partial restraint of marriage will be upheld if they do not unreasonably restrict the freedom of the beneficiary's choice. Where the restraint is not general, but is merely partial or temporary, or otherwise limited in effect, then the condition may or may not be void, according to whether it is considered reasonable or otherwise, and does not operate merely in terrorem. Among the restrictions held reasonable are conditions to marry or not to marry a person of a particular religion. 

Facts:

The United State National Bank of Portland (Oregon), in its capacity as trustee under the last will and testament of decedent C.A. Rinehart, brought this suit against defendant Merle Rinehart Snodgrass, the decedent's married daughter and sole heir, and 17 other defendants who were relatives and contingent beneficiaries of C. A. Rinehart. Plaintiff prays for a declaratory judgment establishing the validity and correct interpretation of the trusts set up by the testament and the rights, if any, of the defendants as beneficiaries thereunder. Snodgrass sought review of a judgment which concluded that the conditions of a bequest to her, declaring a forfeiture of her rights in the corpus of the trust if she married a Catholic before her 32nd birthday, were valid and binding upon her. Snodgrass contended that the restriction upon marriage should not be given effect because it was against public policy and violated her constitutional right to freedom of religion. 

Issue:

Did the lower court err in holding as valid that provision of the will that disinherited potential beneficiary Snodgrass because of her marriage to a member of the Catholic faith before she was 32 years old?

Answer:

No

Conclusion:

The court affirmed the judgment that held the conditions valid. The court stated that a testator's religious views or prejudices could not be questioned on public policy grounds. The court held that a testator had the right to make the enjoyment of his bounty dependent on the condition that the recipient renounce, embrace, or adhere to a particular religious faith. The court held that conditions to marry or not to marry a person of a particular religion were reasonable. The court noted that the constitutional provisions dealing with freedom of religion, U.S. Const. amend. I and Or. Const. art. I, §§ 2 and 3, were restraints upon the government in dealing with citizens and had no bearing on individual actions or transactions.

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