133 Mass. 170 (Mass. 1882)
Broadway National Bank v. Adams is a foundational case in American trust law that firmly recognizes the validity of spendthrift trusts—trusts that restrain a beneficiary's ability to alienate their interest and protect that interest from the beneficiary's creditors.
Whether a testamentary trust provision restraining a beneficiary's alienation of income and protecting that income from the beneficiary's creditors is valid and enforceable, thereby preventing a creditor from reaching unpaid trust income in the trustees' hands or enforcing the beneficiary's purported assignment of it.
A settlor may validly create a spendthrift trust that restrains a beneficiary's voluntary and involuntary alienation of their equitable interest—particularly the right to receive trust income—so that the beneficiary's creditors cannot reach it while held by the trustee, nor can the beneficiary assign it in advance. Such a restraint is not against public policy when the trust is created by a third party (not self-settled). However, once income is actually paid to the beneficiary, it becomes the beneficiary's property and is then subject to creditors' claims.
The spendthrift restraint in the testamentary trust was valid and enforceable. Broadway National Bank could not reach the trust income before payment to Adams, nor could it enforce Adams's purported assignment of future trust income. The trustees' obligation was to pay income only to Adams personally, consistent with the trust's terms.
Broadway National Bank v. Adams is a canonical state-court endorsement of spendthrift trusts and a staple in Trusts & Estates courses. It solidifies several core doctrines: (1) a third-party settlor can restrain alienation of a beneficiary's equitable interest; (2) creditors cannot reach unpaid trust income protected by a valid spendthrift clause; (3) beneficiary assignments of protected interests are ineffective; and (4) once distributions are actually made, creditor remedies attach to the funds. The case also frames the policy debate between creditor rights and settlor intent, a recurring theme on exams and in practice, and it foreshadows the widespread codification of spendthrift protections in modern statutes (e.g., Uniform Trust Code) with well-recognized exceptions and limits.