No estate for life can be limited as a remainder on a term of years, except to a person in being at the creation of such estate. Source: CivC 1877, § 234; CL 1887, § 2750; RCivC 1903, § 257; RC 1919, § 327; SDC 1939, § 51.0418.
Estate for life cannot be limited as a remainder on a term of years--Exception
SDCL § 43-9-9 — under FUTURE ESTATES IN REAL PROPERTY.
SDCL § 43-9-9