nce, and who was not in the State at
the time of an accident, is not subjected to any unconstitutional
deprivation by a law thereof, imposing liability on the owner for the
negligence of one driving the car with the owner's permission.[430]
Compulsory automobile insurance is so plainly valid as to present no
federal question.[431]

Succession to Property

When a New York Decedent Estate Law, effective after 1930, grants for
the first time to a surviving spouse a right of election to take as in
intestacy, and the husband, by executing in 1934 a codicil to his will
drafted in 1929, made this provision operative, his widow,
notwithstanding her waiver in 1922 of any right in her husband's estate,
may avail herself of such right of election. The deceased husband's
heirs cannot contend that the impairment of the widow's waiver by
subsequent legislation deprived his estate of property without due
process of law. Rights of succession to property are of statutory
creation. Accordingly, New York could have conditioned any further
exercise of testamentary power upon the giving of right of election to
the surviving spouse regardless of any waiver however formally
executed.[432]

Administration of Estates.--Even after the creation of
testamentary trust, a State retains the power to devise new and
reasonable directions to the trustee to meet new conditions arising
during its administration, especially such as the depression presented
to trusts containing mortgages. Accordingly, no constitutional right is
violated by the retroactive application to an estate on which
administration had already begun of a statute which had the effect of
taking away a remainderman's right to judicial examination of the
trustee's computation of income. Judicial rules, promulgated prior to
such statute and which were more favorable to the interests of
remaindermen, can be relied upon by the latter only insofar as said
rules were intended to operate retroactively; for the decedent, in whose
estate the remaindermen had an interest, died even before such court
rules were established. If a property right in a particular rule of
income allotment in salvage proceedings vested at all, it would seem to
have done so at the death of the decedent or testator.[433]

Abandoned Property.--As applied to insurance policies on the
lives of New York residents issued by foreign corporations for delivery
in New York, where the insured persons continued to be residents