Spencer v. Riesberry, 2012 ONCA 418 is a lengthy decision dealing with trusts and family law. In the decision the Court made a useful comment about the beneficiary's lack of property interest in the trust res:
 Unless the terms of the trust expressly provide otherwise, a beneficiary has no property interest in any specific asset of the trust, prior to or absent an appropriation of such asset to the beneficiary by the trustee: see Gennaro v. Gennaro (1994), 111 D.L.R. (4th) 379 (Ont. Unif. Fam. Ct.).