A tenant for life has power to dispose of his interest in whole or in part, unless there is a condition in restraint, in the terms of his grant;17 but he can give another no rights in the land which will extend beyond his life.18 There was a common-law rule that a tenant for life forfeited his estate if he attempted to convey a greater interest than he owned, by a conveyance operating through transfer of possession, as by a feoffment in fee,19 because such a feoffment was a renunciation of tenure, and worked a disseisin. But this is not now the rule.20 Life estates are also subject to involuntary alienation, as for taxes and debts.21
17 Criswell v. Grumbling, 107 Pa. St. 408; Hay ward v. Kinney, 84 Mich. 591, 48 N. W. 170.
18 Lehndorf v. Cope, 122 111. 317, 13 N. E. 505; Mclntyre v. Clark, 6 Misc. Rep. 377, 26 N. Y. Supp. 744; Mclendon v. Horton (Ga.) 22 S. E. 45; Fields v. Bush, 94 Ga. G64, 21 S. E. 827.
19 2 Bl. Comm. 274; French v. Rollins, 21 Me. 372. See, also, Stump v. Findlay, 2 Rawle (Pa.) 168. This did not apply to conveyances under the statute of uses. Jackson v. Mancius, 2 Wend. (N. Y.) 357; Pendleton v. Van-devier, 1 Wash. (Va.) 381; Stevens v. Winship, 1 Pick. (Mass.) 318. Nor to a quitclaim in fee. Bell v. Twilight, 22 N. H. 500. Nor to a lease for years. Locke v. Rowell, 47 N. H. 46.
20 Stevens v. Winship, 1 Pick. (Mass.) 318; Rogers v. Moore, 11 Conn. 553; Mccorry v. King's Heirs, 3 Humph. (Tenn.) 267; Mckee's Lessee v. Pfout, 3 Dall. (Pa.) 486; Mcmichael v. Craig (Ala.) 16 South. 883. The conveyances which caused forfeitures were feoffment, fine, and recovery; but these are not now in use. 1 Dembitz, Land Tit. 108.
21 Roberts v. Whiting, 16 Mass. 186; Wheeler v. Gorham, 2 Root (Conn.) 328; Ehrisman v. Sener, 162 Pa. St. 577, 29 Atl. 719; Thompson v. Murphy, 10 Ind. App. 464, 37 N. E. 1094; American Mortg. Co. of Scotland v. Hill, 92 Ga. 297, 18 S. E. 425. But see, as to the life tenant's liability for special assessments, Stilwell v. Doughty, 2 Bradf. Sur. (N. Y.) 311.