FUTURE INTERESTS - LIFE INTEREST WITH ADDED POWER TO DISPOSE OF FEE AS FEE SAMPLE

Given a devise of a life estate plus an absolute power to dispose of the fee, but with a remainder over, on the death of the life tenant, of what then remains undisposed of, does the first taker have a fee or merely a life estate coupled with a power of disposal? In the past, Michigan has been numbered with a small minority of states giving the first taker a fee in this situation, but in the recent case of Quarton v. Barton a contrary result was reached