Village of Peoria Heights v. Keithley
Illinois Supreme Court
132 N.E. 532 (1921)
G.W.H. Gilbert conveyed property to the Village of Peoria Heights (plaintiff) in 1904 on condition that the village pass an ordinance barring bars on the property, which the village did within a month, though it never built anything there. In 1910, Gilbert separately conveyed the same property to Arthur Keithley (defendant) by deed; in 1920, Gilbert quitclaimed to the village any present or future interest he still held in the property, after which the village sued to quiet title and cancel Keithley's deed. The trial court held Keithley had no interest and voided his deed, and Keithley appealed.
Whether, if a grantee holding an estate subject to condition subsequent breaches the condition, the reversionary interest may be held only by the grantor or his heirs.