Womack v. Stegner

W.B. Womack gave his brother D.R. Womack (plaintiff) a deed to mineral rights with the grantee's name left blank, expressly telling him he could name anyone he wished as grantee. After W.B. and later his wife Louise died, Stegner (defendant) inherited Louise's estate by will and argued D.R.'s authority to name a grantee had expired with W.B.'s death, akin to an expired power of attorney, and separately that the deed's lack of consideration defeated any conveyance. The trial court granted Stegner a directed verdict against D.R.'s quiet- title suit.

Whether, under Texas law, the delivery of a deed with express authorization for the recipient to designate a grantee acts to vest title in the recipient.