Gellately vs. United States, 1947, Smithsonian Archives - History Div, Plaintiff filed action to recover the estate of her late husband, John Gellatly, from the Smithsonian Institution. The donations were completed prior to the plaintiff's marriage, and once married, the plaintiff's husband failed to inform her of his intended will. At the time the case was presented, "there [was] no basis in law or in equity to set aside the gift or transfer" or "to allow a recovery." The court ordered that the findings of the case be transmitted to the House of Representatives for resolution..