Cahill v. United States, 810 S.E.2d 480, 483-484, 2018 Ga. LEXIS 97. The Court noted the inapplicability of O.C.G.A. § 44-6-190 (a)(4), enacted after the events in the case. Id., note 2.

The Court of Appeals determined that the language in the deed actually conveyed to the executrix and her husband a life estate in the property as tenants in common and that life estate terminated upon the death of either of them. In reaching this decision, the Court rejected two challenges from the husband’s heir.First, the heir claimed that O.C.G.A. § 44-6-190, which concerns conveyances to two or more persons, applied. The Court rejected this challenge because, while the deed conveyed the life estate to two persons as tenants in common, the deed conveyed the estate in remainder to one person, rather than two.Second, the heir claimed that in the husband’s will, the husband allegedly attempted to devise his interest in the property to his heirs and, thus, the will somehow superseded the deed.