In Brown v. Brown, 61 Tex. 56 (1884), the Texas Supreme Court addressed whether a husband had delivered a real estate deed to his wife. The Court cited a case in which constructive delivery was found when a member of a law firm conveyed title to land to the law firm but retained possession of the deed. Because the grantor was a member of the firm, he had authority to possess the deed on the firm's behalf. Similarly, the husband had authority to possess the deed on his wife's behalf, and if he signed the deed before attesting witnesses, then delivery was complete even though the husband retained possession. The Texas Supreme Court remarked that "the question is one of intention, to be determined from the facts and circumstances preceding, attending and following the transaction."