mahrenholz v. County Board of School Trustees fee simple determinable - ends automatically upon a stated event The future interest that is created in a fee simple determinable is called a possibility of reverter. Example: to School so long as used for school purposes. Traditional language: "to A so long as", "to A until", "to A while", or language stating that upon an event the land is to revert to the grantor. Mahrenholz v. County Board of School Trustees, 417 N.E.2d 138 (1981)Huttons granted land to School board "this land to be used for school purpose only; otherwise to revert to the Grantors herein." The issue here is whether there was a fee simple determinable or a fee simple subject to condition subsequent. The court held that the language "for school purpose only" showed an intent to grant the land to the school only as long as it was needed, thus it was a fee simple determinable. fee simple subject to condition subsequent - may be cut short by grantor's re-entry after a stated event preferred by courts because forfeiture is optional Example: to School, but if premises are not used for school purposes, grantor has right to re-enter and retake. Traditional language: "to A, but if X happens", "to A, upon condition that if X happens", "to A, provided, however , that if X happens".