Palmer v. Flint

A deed conveyed property to Nathan and Alice Palmer "as joint tenants, and not as tenants in common... to the survivor," and after their divorce Alice quitclaimed her rights to Nathan, who later conveyed the property through an intermediary to himself and his sister Roxa (plaintiff) using identical joint-tenancy language; the lower court instead construed the original deed's survivorship language as creating only a life estate with a contingent remainder in the survivor, meaning Alice's quitclaim could not convey her (unvested) contingent interest, complicating the later joint-tenancy conveyance to Roxa. Roxa sought a declaration of her ownership or reformation of the deed.