South Dakota Code § 43-11-19

Effect of absolute power of disposition given to person to whom no particular estate is limited--Rights of creditors, purchasers, and encumbrancers
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Where an absolute power of disposition not accompanied by any trust is given to any person to whom no particular estate is limited, such person also takes a fee subject to any future estate that may be limited thereon but absolute in favor of creditors, purchasers, and encumbrancers.

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