Under the Shelley's Case doctrine historically, the grant 'to A for life, then to A's heirs' would give A a:

• A. Fee simple absolute
• B. Life estate
• C. Contingent remainder in A's heirs
• D. Fee simple subject to a condition

Answer: (A)

Shelley’s Case merges the life estate and the future interest in the life tenant’s heirs into a single, perpetual ownership in the grantee. Here, A is granted a life estate, and the remainder is to A’s heirs. Under the doctrine, the heirs of A are treated as the same person who holds the life estate, so the two interests vest in A as a whole in a fee simple. In other words, the life estate and the future interest in A’s heirs combine to give A full ownership in fee simple now, not a life estate plus a separate remainder. That’s why the grant results in a fee simple absolute for A.