John Townshend, Appellant v. Edward Frommer, Respondents

Summary

The Court affirmed the lower court, holding that the post‑mortem provision in Mrs. Curtis's deed was a valid power in trust, not an express trust, and therefore created only contingent future interests for her children. Those children had no vested estate at the time of the foreclosure, so they were not necessary parties, and the foreclosure extinguished any future interest, leaving the plaintiff without title.