Cy Pres for Reorganized Hospital

The rules of construction for lapsed legacies which are found at 20 Pa.C.S. § 2514(9), (10), and (11) apply only to individuals and so are not relevant to the cy pres doctrine, which the Orphans’ Court properly applied in directing that a share of the income of a charitable trust be paid to the nonprofit community foundation that is the successor to the hospital that was the original beneficiary of the trust and that supports the health care needs of the same community formerly served by the hospital.  In re: Trust Created under the Will of William J. Cohen, 2018 PA Super 138 (5/25/2018).

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