"No interest is good unless it must vest, if at all, not later than twenty-one years after some life in being at the creation of the interest." — John Chipman Gray
Origin: Duke of Norfolk's Case (1682)
Jurisdictions: Still used in some form in ~20 U.S. states without statutory reform.
If an interest violates the classic RAP, the court reforms it "as near as possible" (cy pres) to the testator's intent while satisfying the Rule. Example: age 25 → reduced to 21.
Origin: Adopted in the Second Restatement of Property and by states like CA, TX, MA.
Massachusetts: M.G.L. c. 184A, §2 (wait-and-see + cy pres).
Three-step analysis: (1) Apply classic RAP. (2) If invalid, apply a 90-year wait-and-see period — the interest is valid if it actually vests within 90 years. (3) If still invalid, reform via cy pres.
Origin: Uniform Law Commission, 1986 (amended 1990).
Jurisdictions: Adopted in ~27 states including FL, MA, MN, NV, OR, VA.