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Where the appropriation of the property was unintentional and labor or material has been expended or added which greatly enhances its value, and the value of the original article is insignificant in comparison with the value of the new product, the title to the property in its converted form will pass to the person who has thus expended or added his labor and materials, compensating the owner for the value of the original article or materials.
Plaintiff car dealership bought a car from the defendant car seller that had previously been stolen. Before the car seller came into possession, the car had been stripped and entirely rebuilt by a prior seller. The plaintiff sold the car to the defendant car buyer, from whom the car was stolen. The defendant car buyer refused to pay for the car. The plaintiff car dealership filed a complaint against the defendant car seller and the defendant car buyer. The defendant car buyer filed a cross-claim against the plaintiff car dealership. A chancellor found in favor of the defendant car seller, but against the defendant car buyer. Plaintiff car dealership sought review of the decision.
Did the chancellor err in ruling in favor of the car seller, but against the car buyer?
The court affirmed the decision, holding that the car seller was not liable to the car dealership for sale of a stolen car because the rebuilding of the car from its stripped down hull constituted accession to good title by the prior owner, which was transferred to the car seller and passed to the car buyer. Because the car buyer held good title, the court determined that the chancellor properly granted recovery for the purchase price of the car against the car buyer.