"Freeholds, or estates of indeterminate duration, are in turn divided into estates of inheritance or in fee, and estates not of inheritance, or for life. The former being, where the interest devolves upon successors without end, i. e., when there is no assignable event, certain to happen, upon which the rights will come to an end; the latter is where the interest does not devolve and the rights terminate on the happening of an assignable but uncertain event. At Common Law the former was subject to a further division into absolute and limited estates of inheritance, but this distinction has been abolished in the United States, although a very faint resemblance yet exists in some states.2

1 See Appendix A to Real Property for Charts showing the classification of estates.

2 Warvelle on Real Property, p. 69.