California, United States of America
The following excerpt is from Clark v. Carter, 265 Cal.App.2d 291, 70 Cal.Rptr. 923 (Cal. App. 1968):
In the recent case of Burke v. Stevens, 264 A.C.A. 30, 35, 70 Cal.Rptr. 87, the court impliedly recognized the need for a separate grantor and grantee when it held that a wife had effectively terminated her joint tenancy interest through a deed of her interest to a third party, even though the conveyances by the wife were effected without the knowledge and consent of her husband, who was the remaining joint tenant; the reviewing court noted that the wife had complied with the requisite steps to terminate the joint tenancy inasmuch as she had executed a power of attorney designating her counsel as her attorney-in-fact, with the specific right and duty to terminate the joint tenancy; in compliance with the authority thus conferred, the attorney conveyed the wife's interest in the property by an unacknowledged and unrecorded deed to a
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Foreign authority also exists to the effect that a person cannot convey to himself alone, and if he does so, he still holds under the original title. (26 C.J.S. Deeds 13, p. 600; Strout v. Burgess, 144 Me. 263, 68 A.2d 241, 247, 12 A.L.R.2d 939.)
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