"A bequest to the members composing the School District by name, and to their successors in office, of moneys to be expended in the purchase of books for a district library -- thy being the officers designated by law to preform similar duties for the district -- is in effect a bequest to the district."
Lucy M. Maynard by her last will directed the residue of her estate be sold and the monies be placed at the disposal of the District Board of the Fractional School District in Milan and York, Michigan, and used for library supplies. "The validity of this bequest was attacked by two of the heirs at law."
Cooley, Thomas M. "David Maynard et al v. Fractional School District, & c." Am. L. Reg. 25, no. 6 (1877): 326-331.