Known as the Early Journal Content, this set of works include research articles, news, letters, and other writings published in more than 200 of the oldest leading academic journals. The works date from the mid--seventeenth to the early twentieth centuries. We encourage people to read and share the Early Journal Content openly and to tell others that this resource exists. People may post this content online or redistribute in any way for non--commercial purposes. Read more about Early Journal

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... ntent at http://about.jstor.org/participate--jstor/individuals/early-journal--content. JSTOR is a digital library of academic journals, books, and primary source objects. JSTOR helps people discover, use, and build upon a wide range of content through a powerful research and teaching platform, and preserves this content for future generations. JSTOR is part of ITHAKA, a not--for--profit organization that also includes Ithaka S+R and Portico. For more information about JSTOR, please contact support@jstor.org. COLUMBIA LAW REVIEW COLUMBIA LAW REVIEW COLUMBIA LAW REVIEW made at a time when the parties must have intended to deal with the motion picture rights. The extension of the doctrine of the case of Harper Bros. v. Klaw, supra, to cover the case at bar, makes it impossible for a grantor to enjoy the benefits of that portion of his estate not conveyed away, unless, by express terms, he reserves the right to do so. DEEDS-DELIVERY-EFFECT OF RECORDING.-The plaintiff, being advised by a physician that he might die at any time, made a deed of land to his son reserving a life estate to himself. This deed remained in the custody of the plaintiff except for the time between giving it to the clerk for record and receiving it back after recording. Ee did not intend to give up possession of it unless he became sick. The son knew nothing of the execution and recording of the deed to him. A bill was brought by the plaintiff to cancel the deed. Held, the presumption of delivery by recording was rebutted by the facts of the case. Lynch v. Lynch (Miss. 1920) 83 So. 807. The mere fact of recording a deed is generally held to show a presumption of delivery so far as any acts of the grantor are required. Rogers v. Jones (1916) 172 N. 0. 156, 90 S. E. 117; cf. Guggenheimer v. Lockridge (1894) 39 W. Va. 457, 19 S. E. 874. But this presumption is rebuttable by evidence indicating no intent to pass title. Konser v. Konser (1906) 219 Il. 466, 76 N. E. 846; Hogadone v. Grange Mut. Fire Ins. Co. (1903) 133 Mich. 339, 94 N. W. 1045. Retention of possession of the deed or property by the grantor does not of itself rebut this presumption, either as in the instant case, Valter v. Blavka (1902) 195 ll. 610, 63 N. . E. 499, or where no life estate is reserved. Creighton v. Roe (1905) 218 ll. 619, 75 N. E. 1073; Mitchell v. Ryan (1854) 3 Oh. St. 377. Some states hold that recording is simply evidence to be