Willis: Anglo-American Law 
95 
dues, make the property subject to will, create new convey- 
ances, free estates of dower, and avoid the Statutes of Mort- 
main. As a consequence a campaign against uses was started 
by the king, lords, wives, and heirs, and they finally pro- 
cured the passage of the celebrated Statute of Uses in 1536. 
The object of this statute was to destroy uses. It undertook 
to do this not by making the uses void but by converting the 
uses into legal estates, and making the holder of the legal 
title (seisin) a mere conduit for the title. The statute did 
not apply to leaseholds, copyholds, active trusts, or to second 
uses. Hence the lawyers within a hundred years discovered 
that all that was necessary to keep alive the old law of uses 
was the device of a second use. This revived the equitable 
uses, but after this time they were known as trusts instead 
of uses. However, if the device was not employed, the statute 
would operate. The consequence was that the statute not only 
did not abolish uses, but it transferred into the common law 
all the equitable liberality in regard to estates and conveyanc- 
ing. The common law would not permit a fee simple to be 
cut down by a succeeding estate which would lap back on it; 
nor a gap, when the seisin would be in abeyance. Equity 
permitted both of these things in what were called shifting 
uses, resulting uses, and springing uses. Since the statute 
made the equitable estates legal these estates became good 
common law estates, and were called conditional limitations. 
Suppose A enfeoffed X and his heirs to the use of B for 
life, and one day after B’s death to the use of C and his heirs. 
At common law, prior to 1536, X and his heirs would have 
had an estate in fee simple; and if A had enfeoffed B for 
life, instead of X and his heirs, an estate to begin one day 
after the termination of this life estate would have been void 
and A would have had a reversion in fee. In equity, prior 
to 1536, X and his heirs would have had the legal title, B 
would have had an equitable life estate, A would have had 
an equitable fee simple subject to a condition by way of re- 
sulting use, and C would have had an equitable fee simple to 
take effect as a springing use. After the Statute of Uses 
B would have had a life estate, A a fee simple on condition, 
and C a condition limitation in fee simple. 
Wills. By the Statute of Wills, passed in 1540, devises of 
land by a man’s last will were permitted, as bequests of per- 
sonalty had been permitted from the earliest times. 
