Plyler Doe (1982)
The absolute right to receive title after a presently existing interest in real property terminates. a “vested remainder” is created by deed or by a decree of distribution of an estate given by will. example: “title to the hard luck ranch to my son, sean, subject to a life estate to my brother, douglas.” sean has a “vested remainder” which is an absolute right, sean could sell to another person at this time, with occupancy delayed until title would pass to him.