Ortega owned Blackacre in fee simple and by his will specifically devised Blackacre as follows: "To my daughter, Eugenia, her heirs and assigns, but if Eugenia dies survived by a husband and a child or children, then to Eugenia's husband during his lifetime with remainder to Eugenia's children, their heirs and assigns. Specifically provided, however, that if Eugenia dies survived by a husband and no child, Blackacre is specifically devised to my nephew, Luis, his heirs and assigns." While Ortega's will was in probate, Luis quitclaimed all interest in Blackacre to Eugenia's husband, JosÃ©. Three years later, Eugenia died, survived by JosÃ© but no children. Eugenia left a will devising her interest in Blackacre to JosÃ©. The only applicable statute provides that any interest in land is freely alienable. Luis instituted an appropriate action against JosÃ© to establish title to Blackacre. Judgment should be for
Luis, because his quitclaim deed did not transfer his after-acquired title.  Luis, because JosÃ© took nothing under Ortega's will.  JosÃ©, because Luis had effectively conveyed his interest to JosÃ©.  JosÃ©, because the doctrine of after-acquired title applies to a devise by will