There do not seem to have been any decided cases in the early common law on the question whether a murderer could succeed to the title to property left by his victim, or derive any benefit from his crime. By the civil law the legal title passed to the criminal, and was afterwards confiscated by the state. What may be said to be the modem rule is not so definitely determined, The numerical majority of cases, beginning with the first case to be decided on the exact question in 1888, have held that he could not succeed. But the decisions are not unanimous. They are properly divided into three classifications: those which hold that both legal and equitable title pass to the criminal, those which hold that no title passes, and those which hold that legal title passes but that equity will compel the wrongdoer to hold as a constructive trustee.