When  Virginia  and  those  of  the  Northern  states  that  claimed,
under  their  charters,  a  westward  extension  to  the  Mississippi,  had
transferred  to  the  Confederation  the  lands  of  the  Northwestern

of  "grants,"  made  either  by  towns,  by  bodies  of  •'proprietors,"  or  by  the
agents  of  Eastern  lands  Oands  in  Maine),  or  by  the  legislature;  most  of  them
quite  early,  none  later  than  1806.  The  more  important  are  Mayo  y.  Libby,  12
Mass.  339  (resolution  of  legislature  relinquishing  public  lands  operates  as  grant
in  praesenti);  Springfield  y.  Miller,  Id.  415  (a  town  may  grant  by  yote);
Thomas  y.  Marshfleld,  10  Pick.  304  (no  consideration  need  be  shown  for  grant
by  town).  Ipswich  Grammar  School  v.  Andrews,  8  Mete.  (Mass.)  584,  is  of
historic  interest,  deciding  that  a  grant  made  in  lOoO  carried  a  fee  without  words
of  limitation,  for  lack  of  legal  lore  at  that  time.  In  Boston  y.  Richardson,  13
AUen,  146,  is  said  that  the  rule  construing  public  grants  most  strongly  against
the  grantee  applies  only  when  the  grant  is  ambiguous,  and  no  other  i-ule  can
be  found  to  determine  the  meaning.
