Charles Evans BMW, Inc. v. Williams
Court of Appeals of Georgia
395 S.E.2d 650 (1990)
Williams (defendant) agreed to sell his car to Hodge and accepted a cashier's check as payment; he signed the title over and delivered the car and title to Hodge. Hodge, impersonating Williams, then sold the car to Charles Evans BMW, Inc. (plaintiff) and pocketed a check made out to Williams, later cashing it using Williams's driver's-license number. Evans BMW resold the car. Williams then discovered Hodge's cashier's check had been a forgery. After police located the resold car, Evans BMW had to refund the resale price and return the car to Williams, but kept the title and sued Williams, claiming it was a good-faith purchaser for value. The trial court sided with Williams, and Evans BMW appealed.
Whether a party who unknowingly purchases goods from a fraudulent seller holding voidable title qualifies as a good-faith purchaser for value entitled to keep the goods.