"A deed is delivered as an escrow, when the delivery is conditional, that is, when it is delivered to a third person, to keep until something be done by the grantee; and it is of no force until the condition be fulfilled. The condition may consist in the payment of money as well as in the performance of any other act."
- Jackson, ex. dem. Gratz et al. v. Catlin, 2 Johns. 248 (pincite unavailable) (S. Ct. N.Y. 1807).