Sam died unexpectedly in 2010. At Sam's death, his will included the following language: "I leave my land on Frying Pan River "to John Smith. It is my hope that the land will never be sold." Two years later, Client comes to you for advice regarding the purchase of the land from John Smith. How would you characterize the status of title now owned by Smith? a-Smith likelv owns a fee simple absolute since most courts will conclude that the expression that the land "never be sold" is an invalid restraint on alienation. b-Smith likely owns a fee simple subject to a condition subsequent with a right of entry held by Sam's Estate. c-Smith likely owns a life estate with a reversion in Sam's Estate. d-Smith likely owns a fee simple absolute with an enforceable covenant that the land will never be sold.