City of Manhattan Beach v. Superior Court

In City of Manhattan Beach v. Superior Court (1996) 13 Cal. 4th 232, the granting clause included a reference to a railroad right-of-way. The deed stated, in part, that the grantors, in return for $ 1, did "remise, release and quit-claim" to a railway the right-of-way for the construction, maintenance, and operation of a railroad over a designated parcel. (Manhattan Beach, supra, 13 Cal. 4th at p. 236.) The juxtaposition of the conveyance by quitclaim of the grantor's entire interest with a statement that it was for a right-of-way created an ambiguity as to whether an easement (a mere right of use) was conveyed as opposed to a fee interest.