Under Shelley's rule, if a conveyance gives a life estate to grantee with remainder to grantee's heirs, what is the result at common law and how would modern rules treat this?

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Shelley’s Case asks what happens when a grant uses language that looks like a life estate to A followed by a future interest to A’s heirs. The idea is that a life estate cannot last beyond A’s life, and the phrase “A’s heirs” is treated as if it were a limitation on A’s ownership rather than a separate, distinct class of takers. Under the old rule, the life estate and the future interest to A’s heirs merge, so the grantee ends up with the entire thing as a fee simple absolute. In other words, at common law the grantee would hold a full ownership—no reversion to the grantor and no separate future interest in heirs.

Modern treatment largely abolishes Shelley's Rule in many jurisdictions. If abolished, the grant is read as a life estate to the grantee with a remainder to the grantee’s heirs that can vest in the heirs after the grantee’s death. The property does not automatically become the grantee’s fee simple; the heirs have a present right that can vest, and the grantor would only have a reversion if the heirs cannot take (or if the line dies out). So, at common law the result is a fee simple in the grantee, while modern rules typically treat it as a life estate plus a remainder to the grantee’s heirs.