Robben v. Obering
United States Court of Appeals for the Seventh Circuit
279 F.2d 381 (1960)
Ed Meirink leased oil-and-gas rights to Obering (defendant) with a covenant warranting good title, but a later title search showed Meirink actually owned only a one-quarter interest, with the rest split among his siblings and a nephew. Meirink's brother Arthur conveyed his own quarter interest to Meirink by quitclaim deed, and Meirink then returned it to Arthur once he realized he couldn't get deeds from the other relatives; Arthur then leased that same quarter interest to Robben (plaintiff). Robben sued for a declaratory judgment recognizing his rights under that second lease, and the district court ruled in his favor, prompting Obering's appeal.
Whether, under Illinois law, the doctrine of after-acquired title is limited to conveyances of title in fee simple absolute.