In Quinn v. Pere Marquette R Co, 256 Mich 143, 151-153; 239 NW 376 (1931), a deed to a railroad was determined to unambiguously create a determinable fee subject to a condition subsequent. The grantors provided a warranty deed to the railway, providing a strip of land one-hundred feet wide for railroad purposes only. Id. at 146-147. The Quinn deed did not contain reversionary language. The Court noted that "right-of-way" had two meanings in railway parlance, potentially meaning both the strip of land upon which the track is laid and the legal right to use the strip. Id. The Court reasoned that the grant was for a determinable fee when the deed contains an express intended purpose for the grant and a reverter clause. Id. at 154-155.