In re Estate of Michael
Supreme Court of Pennsylvania
218 A.2d 338 (1966)
A deed conveyed a farm to "Harry L. Michael and Bertha M. Michael, his wife, tenants by the entireties and Ford W. Michael and Helen M. Michael, his wife, as tenants by the entireties with right of survivorship," with Ford being Harry and Bertha's son; after Harry predeceased Bertha, and Bertha's will left the farm to her other son Robert (with a $1,000 alternative gift to Ford), the probate court had to determine Bertha's actual interest based on the deed's ambiguous survivorship language, ultimately concluding the clause gave Ford and Helen a right of survivorship that vested full fee title in them once both Harry and Bertha died; Robert appealed.
Whether Pennsylvania's Act of 1812 disfavors rights of survivorship and creates a presumption of tenancy in common absent a clear expression of the grantor's intent to establish a right of survivorship.