Title in fee simple means full and unconditional ownership.
The following are examples of case law on title in fee simple:
A good title in fee simple is necessarily marketable and unencumbered for it is a title to the whole property absolutely. [Lea v. Bridgeman, 228 N.C. 565 (N.C. 1948)].
Real estate deeded to the bank by warranty deed, but in fact for security only, would not be held by title in fee simple. [First Nat'l Bank v. Moon, 102 Kan. 334, 344 (Kan. 1918)].