1.How the Fee Simple Developed
 a.Rise of Heritability
  i.Fee literally refers to the tenant’s holding or fief
  ii.As the fee concept progressed in Feudal England, the demand for land created a right in the tenant to sell his fee, or holding during his life, to others without the consent of the landlord
  iii.This right created the alienability of the fee, or holding, and eventually led to fee simple
 b.Rise of Alienability
  i.Definition
   1.The ability to freely convey your interest, or a lesser interest in the property
  ii.Alienability rests on the idea of abstraction
   1.Abstraction = the estate in land is separate from the land itself
  iii.Creditors are now able to reach the fee simple and sell it to pay debts
  iv.This rise in alienability creates an “absolute ownership” of real property
 c.Rise of Fee Simple Estate
  i.Today Fee Simple is the default position in cases of ambiguous conveyance
  ii.Common Law Rule was that ambiguities in a conveyance were resolved in favor of a life estate – lack of the magic words would create a life estate
  iii.Once fee simple fully established, real property became fully alienable and inheritable