Brown v. Lober (Ill. 1979): Grantee attempts to extend the protection afforded by the warranty and quiet enjoyment by claiming constructive eviction because he did not own what his warranty deed purported to convey.  The covenant of warranty or quiet enjoyment is prospective in nature and is breached only when there is an actual or constructive eviction (ex. grantee buys the paramount title in order to avoid being evicted by its holder) of the covenant by the paramount titleholder.