• The case that gave rise to this fiction was Jee v. Audley, 1 Cox 324, 29 Eng. Rep. 1186 (ch. 1787). See W. Barton Leach, Perpetuities: New Hampshire Defertilizes Octogenarians, 77 Harv. L. Rev. 729 (1963).
— Also termed presumption-of-fertility rule.