Metzger v. Miller
United States District Court for the Northern District of California
291 F. 780 (1923)
Karoline Schwab, a German citizen, inherited Sacramento property and money from her deceased sister. She wrote several letters to her son Metzger (plaintiff), a naturalized U.S. citizen, stating that she wanted him to have the inherited property and that she only wanted to keep the money from her sister's estate. In 1917, Miller (defendant) seized the property under the Trading with the Enemy Act, which allowed seizure of property belonging to enemy nationals. Metzger sued, arguing the property had already been conveyed to him — a U.S. citizen — before the seizure, and so could not be lawfully seized.
Whether a court will give effect to a deed, even without technical conveyancing language, when it can discern a clear intention to convey an interest in property.