Do Stock Splits Increase the Number of Shares Listed In a Will ?

In In re Woodward Estate, 407 Pa. 638, 182 A.2d 732 (1962), the decedent bequeathed "thirty shares of [AT&T] stock" to Vera Walls and "thirty-five shares of [AT&T] stock" to Henry Walls. Woodward, 407 Pa. at 639, 182 A.2d at 732. At the time the decedent wrote the will, she owned a total of 143 shares. A residuary clause granted the remainder of the estate to various nieces and nephews. Before she died, AT&T stock split three-for-one; accordingly, the decedent owned 429 shares at the time of her death. Vera and Henry Walls argued that in light of the stock split, they were entitled to three times the number of shares listed in the will. Our Supreme Court rejected this claim, reasoning as follows: She clearly said at the time she made her will that she wished to give 30 shares to Vera and 35 shares to Henry and she wished her residuary estate to be divided among her five named nephews and nieces. Two years later, the A.T. and T. stock was split three-for-one.