Thursday, October 11, 2012

McAvoy v. Medina (1866) (misplaced, not lost wallet)


a.       Facts- P went into D’s shop and found a wallet on a table. P notified D of the find. P told D to give it to the true owner, if said true owner should claim it. True owner did not claim it, upon which P demanded the money from D. D did not submit said money. P sued D for the sum of found money.
b.      Procedural History- Ct ruled that P could not bring action against D. P alleged exceptions
c.       Issue- Whether P can bring action against D for chattel that was not considered to be lost, but mislaid
                                                              i.      Was the wallet in question “lost”?
d.      Holding- No, P cannot bring action against D for chattel that was not considered to be lost, but misplaced
e.       Rule- Chattels which are “misplaced” must be construed as such, and not as “lost”. Therefore, rules of “lost” chattel are not applicable to “misplaced” chattel
f.       Rationale- The wallet was found upon a table, presuming that the true owner placed the wallet there intending to pick it up again. By failing to pick it up later, true owner has not lost the wallet, but misplaced it
g.      Notes-
                                                              i.      Intention of the true owner comes into play
                                                            ii.      Chattel must be “lost” in order to be “found”
                                                          iii.      If item is mislaid, owner of property which it is found has the duty to deliver to employer or to “take reasonable care for the safe keeping of chattel until the delivery to true owner”
                                                          iv.      If item is mislaid, rights go to owner of locus in quo
                                                            v.      Mislaid:
1.      Awareness that item is in specific place, AND
2.      Intention of taking back
                                                          vi.      POLICY: It’s not strictly about the true owner coming back to claim it…but about “when something is mislaid by the customer, it is the duty of the shopkeeper to hold the item until the customer comes back for it”…which gives the shopkeeper the possessory interest
                                                        vii.      If we leave “mislaid” items w/ the owner of locus, the true owner can come back to claim…because people who “mislay” things have some idea where they parted w/ their item
                                                      viii.      The problem is that it doesn’t give good incentive for the finder to hand over the “lost” item

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