Dickson v. Alexandria Hospital
United States Court of Appeals for the Fourth Circuit
177 F.2d 876 (1949)
George Simpson's will left the remainder of his estate to his wife Virginia, conditioned on her not remarrying, with the remainder passing to his two sons if she did remarry; Virginia died in 1944 without remarrying, and Dickson (plaintiff), the widow of one deceased son, sued claiming George's will had only created a defeasible life estate in Virginia, half of which should have passed through her deceased husband to Dickson, but the district court found George's will instead gave Virginia a defeasible fee simple that became absolute upon her death without remarriage.
Whether, under Virginia law, if real estate is granted without any words of limitation, any interest the grantor had in the real estate passes to the grantee unless the will contains a contrary intention.