In Mulford v. Hiers, 13 N.J. Eq. 13, 14-15 (Ch.1860), the Chancery judge considered the case of a widow who consented, in writing, to receive a gross sum in lieu of her dower, but died before all the subject lands were sold. 13 N.J. Eq. at 14. On January 15, 1857, the widow filed for her deceased husband's lands to be partitioned. Id. at 13. The court granted that motion one year later on January 18, 1858, and in March 1858, the first portion of the real estate was sold. Id. at 14. In September 1858, the widow consented, in writing, to receive a gross sum instead of her dower, but then died on October 18, 1858, before distribution of the sale proceeds. Ibid. One month later, on November 27, 1858, the second portion of the husband's lands was sold. Ibid. The widow's children claimed an entitlement to the cash that represented their mother's interest when it came time for distribution of the sale proceeds. Ibid. The children of the husband's first marriage argued that their half-siblings were entitled to nothing because their mother passed away before the proceeds were distributed. Ibid. The Chancellor specifically distinguished the properties that had been sold before her death from those sold afterward. Ibid. The court stated: so far as relates to the proceeds of the sale of . . . the land which was sold after the death of the widow, it is clear that her children can have no claim in virtue of her right of dower. . . . No sale of the dower right was ever made, and consequently there are no proceeds of the sale which the widow could be entitled to have invested for her benefit, or in lieu of which she could receive a sum in gross. But in regard to the sales which were made and confirmed in the lifetime of the widow, her children are entitled to receive out of the proceeds of the sale a just and reasonable satisfaction for their mother's interest. Id. at 14-15.