Dower attaches to determinable estates,113 but is defeated by the happening of the event which terminates the estate.114 If this occurs before the husband's death, dower never becomes consummate; if after his death, the enjoyment of the land assigned as dower is cut off.

109 Stoughton v. Leigh, 1 Taunt 402; Lenfers v. Henke, 73 111. 405; Coates v. Cheever, 1 Cow. (N. Y.) 460; Billings v. Taylor, 10 Pick. (Mass.) 460; Moore v. Rollins, 45 Me. 493; Hendrix v. Mcbeth, 61 Ind. 473; cf. Black v. Mining Co., 49 Fed. 549. But see, as to mining leases, Seager v. Mccabe, 92 Mich. 186, 52 N. W. 299; Priddy v. Griffith, 150 111. 560, 37 N. E. 999. There is no dower in a mining claim. Black v. Mining Co., 3 C. C. A. 312, 52 Fed. 859.

110 Spangler v. Stanler, 1 Md. Ch. 36; Butler v. Cheatham, 8 Bush (Ky.) 594.

111 Co. Litt 40a; 1 Scrib. Dower (2d Ed.) 227. At common law the widow must be at least nine, as women have become mothers at that age, but a woman is never presumed to be too old to bear children. 2 Bl Comm. 131; 1 Scrib. Dower (2d Ed.) 229.

112 Ante, p. 73.

113 Such as estates upon condition or limitation. See. post, p. 169.

114 Beardslee v. Beardslee, 5 Barb. (N. Y.) 324; Greene v. Reynolds, 72 Hun, 565, 25 N. Y. Supp. 625; Peay v. Peay, 2 Rich. Eq. (S. C.) 409; Moore v. Esty, 5 N. H. 469; Jackson v. Kip, 8 N. J. Law, 241; Northcut v. Whipp, 12 B. Mon. (Ky.) 65. That there is dower in a fee subject to an executory devise, see Moody v. King, 2 Bing. 447; Weller v. Weller, 28 Barb. (N. Y.) 588; Clark v. Clark, 84 Hun, 362, 32 N. Y. Supp. 325; Evans v. Evans, 9 Pa. St 190. Pollard v. Slaughter, 92 N. C. 72; Milledge v. Lamar, 4 De-saus. Eq. (S. C.) 617; Jones v. Hughes, 27 Grat (Va.) 560; Medley v. Medley, Id. 568. Contra, Edwards v. Bibb, 54 Ala. 475,