Also known as: reversionary estate · estate in reversionary interest · reversion
Written by attorneys · grounded in primary & secondary sources — see below
A future interest in land that remains in the grantor after conveying a lesser estate such as a life estate or term of years. It arises by operation of law when the grantor does not dispose of the entire interest originally held.
Erika Echevarria leased her warehouse to Empire Logistics under a deed that included an affirmative covenant to maintain the loading docks. Empire performed the repairs itself rather than requiring Erika to act from her retained future interest. The covenant burden ran with the leasehold because performance was more reasonable for the possessor than for the holder of the future interest.
Emerald Enterprises merged into Eclipse Manufacturing. All contracts and real property interests held by Emerald passed directly to Eclipse. No future interest remained with Emerald because the merger statute transferred every asset without creating any retained estate in the disappearing entity.
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Eduardo Enriquez held an estate in fee tail in a family farm. Upon his death the land passed to his specified issue under the deed. The future interest that would have returned to the original grantor never arose because the limitation directed the property to the lineal descendants instead.
Enzo Eastwood's LLC merged with another entity. The surviving company received title to all real estate owned by the disappearing LLC. No estate in reversion was preserved for the merged entity because the uniform act vested every property interest directly in the survivor.
Eileen Epstein created a fee tail limited to a single lifetime. At the tenant's death the land passed to the designated issue in fee simple. The reversion that would otherwise have returned to Eileen never took effect because the gift form directed the property to the specified heirs.
Emma Erickson received a legislative grant of coastal acreage. When a later statute attempted to reclaim the land, the court examined whether any future interest had been retained by the state. The original conveyance had transferred the entire estate, leaving no reversionary interest that could support the reclamation claim.
An estate in reversion remains in the grantor by operation of law when the grantor conveys a lesser estate without disposing of the entire interest. A remainder is a future interest created in a third party that follows the prior estate. The distinction matters because only a reversion arises automatically in the transferor.
Supporting sources
No. Modern statutes abolish the doctrine as both a rule of law and a rule of construction. Language such as remainder to my heirs at law or next of kin does not presumptively retain a future interest in the transferor. The remainder interest passes to the designated class instead.
Supporting sources
A power of termination arises when a grantor conveys a fee simple subject to condition subsequent and expressly reserves the right to reenter upon breach. An estate in reversion arises automatically when the grantor conveys a life estate or term of years without further disposition. The two future interests are created by different deed language and carry different transferability rules.
Supporting sources
…in Berman extended beyond that to encompass the purpose of developing that area to create conditions that would prevent a reversion to blight in the future. See 348 U. S., at 34-35 ("It was not enough, [the experts] believed, to remove existing buildings that were insanitary or unsightly. It was important to redesign…