Ballard v. Wetzel
Tennessee Court of Appeals
1997 Tenn. App. LEXIS 699 (Oct. 16, 1997)
Relevant factsFree
Ballard's (plaintiff's) car was totaled in an accident; her son, without her knowledge, sold the wrecked hull to George Martin, who did not know the son lacked good title. Johnny Wetzel (defendant) then bought the hull from Martin for $900 and spent about 100 hours and $5,000 restoring it, raising its value to about $7,950. Ballard sued Wetzel to recover the car, and the trial court held Wetzel had acquired title by accession; Ballard appealed.
IssueFree
Whether void title to stolen property may pass by accession to a bona fide purchaser when the purchaser's labor or materials create a significant disparity between the original and enhanced value.