In Gong v. Jeong, Docket No. BER-C-96-14, 2015 N.J. Super. Unpub. Lexis 427 (Ch. Div. Mar. 3, 2015), a New Jersey Chancery Court reaffirmed the principle that there is no "enforceable right in the expectancy of an inheritance" under New Jersey law. In Gong, plaintiff sued to void the transfer of a commercial property that plaintiff claimed his father had promised to bequeath to him. Plaintiff's father died without leaving a will or any other writing indicating his intention to leave the property to the plaintiff. The Court dismissed plaintiff's claims, finding that the property passed to plaintiff's mother as a matter of law upon plaintiff's father's death.
Likewise, in Roy v. McInerney, HHDCV146049411S, 2015 Conn. Super. Lexis 699 (Conn. Super. Mar. 30, 2015) a Connecticut Superior Court dismissed claims based upon an alleged oral promise, without consideration, to convey property in the future.
In 1955, Anthony and Sara Tordonato purchased real property in Old Saybrook, CT. In 1967, the Tordonatos conveyed the property to their daughter, Janet, and her husband. In 1971, Janet signed a letter promising her sister, Concetta, that if she sold the property while Concetta was alive, one-half of the proceeds would be paid to Concetta, but if she sold the property after Concetta died, then one-half of the proceeds would go to Concetta's living children in equal shares. Concetta died in 2008 and was survived by her five children. In 2013, Janet conveyed the property to her daughter, Karen, who then conveyed the property to her brother, John.
Concetta's children filed suit, alleging that John and Karen repudiated the promise. The Court dismissed the Complaint, finding, among other things, that the letter signed by Janet constituted an unenforceable promise to make a gift in the future because it was not supported by consideration.