Sheridan Suzuki, Inc. v. Caruso Auto Sales

Facts

Bouton uses bad check to purchase a Suzuki bike. Bouton sells day old Suzuki bike to Caruso Auto promising that he will send the title in the mail to Caruso. Caruso checks with Suzuki first to make sure that the bike is really Bouton’s. Suzuki, having not received word that the check bounced, tells Caruso that the bike is really his. Suzuki/Plaintiff wants to recover the bike from Caruso/Defendant.

Issue

Is Caruso’s purchase of the bike an example of bona fide ownership?

Arguments for Both Parties

Defendant states that Suzuki is estopped, or is unable to keep Defendant from ownership because Bouton had properly received ownership of the bike. Defendant also states that he relied on the statement of Plaintiff, which encouraged the idea that the seller’s ownership was real and actual. Plaintiff states that since Bouton never received official title, he was never the owner of the bike, only possessor in fault.

Plaintiff states that since Bouton never had a perfect title, he could never pass ownership rights.

Holding

Court holds for Plaintiff stating that defendant never had anything but the rights that Bouton had, which were no more than illegal possession. Court gives summary judgment to Plaintiff.

Rule

In common law, a thief can pass no title whatsoever to stolen goods.

A BFP can receive a good title from a person with a voidable interest in said property, but a voidable title for a property cannot be changed into a good title by virtue of selling it to a purchaser who does so in good faith.

Policy Arguments

The holding of this case supports actual bona fide ownership, which encourages lost and found items to enter commerce, and reprimands those who would steal to enter the marketplace with stolen goods.

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