Duquesne Law Review


A bequest for Masses is a testamentary gift to a Roman Catholic religious agency, coupled with a request that Masses be celebrated on the decedent's behalf. English courts during the Reformation voided bequests for Masses as illegal and superstitious. Modern courts generally hold them valid as charitable trusts, although poorly drafted bequests can run afoul of state Mortmain, lapse and charitable trust statutes. The author examines the checkered legal history of bequests for Masses and concludes that problems often arise because courts may not understand that a bequest for Masses is not payment for religious services to benefit one person.

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