Ford v. Allen Court of Appeals of Texas, 1975. Facts: The plaintiff was the only son of Chester and Lola Ford, who died within a month of one another. They each had holographic wills that left their property to the other. Specifically, Mr. Ford, who died first, had written a will with the following relevant language, “I divide all my property to my...wife...to do with as she see fit except that she not Sell, Mortgage, or Lease any of our real estate for more than three years without the written consent of our son (Plaintiff).” Defendants were the estranged grandchildren of Lola Ford’s from a previous marriage. Procedural History: The trial court held that the limitations imposed on Lola Ford in Chester’s will was void as being a restraint on alienation and repugnant to the devise in fee, and that the language of the will created a fee simple in all property for Lola Ford. P appealed, arguing that the language was ambiguous as to the estate granted to Lola Ford, and that in order to solve this ambiguity, P offered various evidence that Chester Ford had not intended to leave the property to Defendants. Issue: Can external evidence be used to read in an ambiguity to language whose plain meaning is unambiguous? Can a court refuse to enforce a limitation on alienation of a property interest granted in a will? Holding: No, and yes. Reasoning: Courts can refuse to enforce certain restrictions on property interests in accordance with the common law policy against restrictions on alienation and the doctrine of numerus clausus (grantors cannot create their own estates with new restrictions; must be limited to established estates within the common law).