Patrick Henry v. W. H. Phillips

Summary

The Texas Supreme Court held that a deed placed in escrow with the grantor's expressed intent to deliver it after his death constitutes a valid delivery that vests title in the grantees at the grantor's death. The Court also found that evidence of the grantor's later offers to sell the land and the envelope endorsement were immaterial to the delivery issue, and it reversed the Court of Civil Appeals while affirming the trial court's judgment for the grantees.