In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe CollegeAnnotate this Case
The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted.
A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present.