Opening Word document…
‘Should’ refers to the future.
Brown ’8 [Mary Ann Brown; May 14; Judge on the Court of Appeals of Iowa; Westlaw, “In re Est. of Guthrie,” 752 N.W.2d 452]
Brock and Kaitlyn look to the word “should” in the phrase “in the event any of my children should predecease me” and claim the district court improperly found the word looked to the future. They claim the word should be interpreted as the past tense of “shall” to imply a duty or obligation. See Black's Law Dictionary 1379 (6th ed.1990). Looking at the phrase as a whole, however, rather than at a single word, we determine the phrase is considering possible future events. See In re Estate of Grulke, 546 N.W.2d 626, 627 (Iowa Ct.App.1996) (noting we must ascertain a testator's intent from the entire will).
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