Michael F. McMahon, Property Law: Legislative Solution for Washington Courts’ Disfavor of Land Forfeitures. Martin v. City of Seattle, 111 Wn.2d 727, 765 P.2d 257 (1988), 25 Gonz. L. Rev. 157 (1989).
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The Washington Supreme Court held in Martin v. City of Seattle that a condition subsequent in a deed which placed restrictions on a parcel of land other than the land conveyed is invalid as a matter of public policy. Furthermore, the court found that the power of termination had expired because neither the grantor nor its successor had exercised the power of termination within a reasonable time after the condition was breached.