In May 2001, Fred Parramore executed four deeds, each conveying a life estate in his land to him and his wife and a remainder interest in one-fourth of his land to each of his four children: Alney, Eudell, Bernice, and Iris. Although Fred executed and acknowledged the four deeds as part of his plan to distribute his estate at his death, he did not deliver them to his children at this time. Instead, he placed the deeds with his will in a safe deposit box and instructed the children to pick up their deeds at his death. Fred later conveyed Alney’s deed to Alney, thereby vesting Alney’s interest in that parcel, but Eudell, Bernice, and Iris’s deeds were never handed over to them during Fred’s lifetime. Fred, however, acted as if the land were beyond his control, and on one occasion told a prospective buyer that the land had already been deeded away. When Fred died in November 2011, Alney brought this action, claiming that the deeds to Eudell, Bernice, and Iris were ineffective because they had never been handed over during Fred’s lifetime.
Accordingly, Alney argued, the remaining land should pass in equal shares to each of the four children under the residuary clause of Fred’s will. Who will prevail? Why?