Stoller v. Doyle
Supreme Court of Illinois
100 N.E. 959 (1913)
Lawrence Doyle conveyed a warranty deed to Frank Doyle including language that would cause title to revert to Lawrence in the event that Frank died leaving no surviving children. In the event that Frank was survived by children, his wife would take a life estate in the property and the children would take fee simple title upon the death of the wife. Lawrence Doyle later executed a second deed to Frank Doyle for the same property with no restrictions. The second deed expressly stated that it was intended to remove the restrictions of the first deed. Frank Doyle later sold the land by warranty deed to John Stoller (defendant). Stoller in turn attempted to sell the property to another party, but the sale fell through when the title abstract concluded that Stoller could not convey marketable title. Stoller and the putative purchaser litigated the issue of the marketability of Stoller’s title. The state supreme court ultimately affirmed the trial court’s conclusion that the first deed issued by Lawrence Doyle conveyed a remainder interest to Frank Doyle’s children that could not be destroyed by the second, unconditional deed. Stoller filed a quiet title action against Frank Doyle’s wife and children. The court appointed a guardian ad litem to represent the interest of Doyle’s minor children. The circuit court concluded that Stoller held fee simple title and ruled in his favor. Doyle’s wife and adult children did not appeal, but the guardian ad litem for Doyle’s minor children (defendants) petitioned the state supreme court for review.
Rule of Law
Holding and Reasoning (Yeager, D.J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 166,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.