Federal Circuit: Chicago Coating Company v. US

As the deeds of conveyance to the railway were in quitclaim form, a presumption of conveyance in fee simple arises.  Reference in one case to a right of way is insufficient to overcome this presumption, as it was likely used to identify the existing easement that ran across the property to be conveyed.  Right of re-entry doesn't argue either way, but a reverter in the second deed further reinforces the conveyance in fee simple.  Etc, etc.