Abramovic v. Brunken

In Abramovic v. Brunken (1971) 16 Cal.App.3d 719, testator executed a will in 1940 leaving to his son a life estate with a remainder over to the son's "children." Shortly before the son's death in 1954, the son adopted his 32-year-old stepdaughter. There was evidence that in 1941 when the son married the stepdaughter's mother, the stepdaughter was 19 years of age, already working and contemplating marriage -- in short, functioning as an adult. (Id., 16 Cal.App.3d at p. 722.)