Earle v. Fiske
Supreme Court of Massachusetts
103 Mass. 491 (1870)
Relevant factsFree
Nancy Fiske executed a deed granting a life estate to her son Benjamin and his wife Elizabeth, with fee simple title passing to Mary Fiske upon the life estate's end, but this deed was not recorded until 1867, two years after Nancy's death. Before that recording, Benjamin conveyed the property to Earle (plaintiff) in 1866, and when Earle sued to quiet title against Elizabeth and Mary (defendants), the trial court held Nancy's earlier deed had already conveyed her full interest, meaning Benjamin never inherited fee title to pass to Earle.
IssueFree
Whether, under Massachusetts law, an unrecorded deed has any adverse effect on the rights of a bona fide purchaser.