Since chattels personal were never subjects of feudal tenure,' the creation of legal interests in them is not restricted by the artificial rules which apply in the creation of legal interests in realty. Though it may be proper to speak of the seisin of chattels, there has never been a principle that such seisin cannot be put in abeyance. Land can only be held of some one, but chattels may be owned absolutely. Strictly speaking, estates in chattels are therefore impossible, for estate connotes qualified ownership. Any disposition of a chattel, unless it be by way of pledge or bailment, or unless otherwise limited, will pass the absolute interest in it. Words of limitation are unnecessary; while a conveyance of land to A formerly passed but a life estate,' a similar gift of a chattel made him absolute owner.
Manley O. Hudson,
Limitations of Personal Property,
4 Bulletin Law Series.
Available at: https://scholarship.law.missouri.edu/ls/vol4/iss1/3