Oliver Wendell Holmes, Jr., Waskey v. Chambers — Opinion of the Court
“ The circuit court of appeals went on the ground that a lease creates only a chattel interest, and is not a conveyance, and therefore is not within the protection of the statute. But it is obvious that in principle the right of a lessee is the same as that of a purchaser in fee, and it would be a great misfortune, especially to mining interests, if a man taking a lease from those whom the record showed and he believed to be the owners, were liable, after spending large sums of money on the faith of it, to be turned out by an undisclosed claimant, on the strength of an unrecorded deed. ”
