Commonwealth v. Car Pawn of Virginia, Inc.

37 Va. Cir. 412, 1995 Va. Cir. LEXIS 1124
CourtRichmond County Circuit Court
DecidedDecember 5, 1995
DocketCase No. HG-402-3
StatusPublished

This text of 37 Va. Cir. 412 (Commonwealth v. Car Pawn of Virginia, Inc.) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Car Pawn of Virginia, Inc., 37 Va. Cir. 412, 1995 Va. Cir. LEXIS 1124 (Va. Super. Ct. 1995).

Opinion

By Judge T. J. Markow

This matter came before the court on October 11,1995, for argument on the Commonwealth’s Motion for Summary Judgment. The parties stipulated to all the relevant facts concerning the matter and conceded that the remaining issues are questions of law. This court will decide whether certificates of title to automobiles are a proper subject of pawn, whether Car Pawn of Virginia is a bona fide pawnbroker, and whether the defendant has violated the Consumer Finance Act (CFA), Collision Damage Waiver Act (CDWA), the Virginia Consumer Protection Act (VCPA), or the Virginia Pawnbroker Statute (VPS).

The stipulated facts are summarized as follows. Car Pawn, a Virginia corporation, was licensed as a pawnbroker by the Circuit Court for the City of Norfolk on September 30, 1993. The business does not have and has never held a finance license from the State Corporation Commission. It advertises in various publications circulated on military bases and in stores in Tidewater Virginia. Car Pawn’s business plan involves lending money in amounts from $100 to $2,500 to consumers who agree to pawn their automobiles as security but who are allowed to retain possession by an ostensible lease-back from Car Pawn. The certificate of title to the vehicle and a set of keys remain with Car Pawn during the transaction. The customer receives a pawn ticket.

[413]*413Persons who wish to rent their car during the loan period enter a rental agreement obligating them to pay, in addition to the principal amount, a monthly damage waiver fee (20% of the loan) if the vehicle is not covered by collision insurance. If the customer’s vehicle is covered by collision insurance, Car Pawn could be added to the insurance policy without an additional charge by the insurer. Adding Car Pawn as an insured eliminates the damage waiver fee from the customer’s charges. Prior to October, 1994, even customers with collision insurance were required to pay the damage waiver fee. Car Pawn also required customers, as of January, 1995, to sign an option statement to either leave the vehicle with Car Pawn, place Car Pawn on their insurance policy, or purchase the limited damage waiver. In practice, few, if any, customers left their cars with Car Pawn. In fact, its advertisements touted that one could borrow by pawning his car but still have the use of the car.

The principal amount of Car Pawn loans includes the damage waiver fee. Each loan costs the 'consumer interest amounting to an annual percentage rate of 60% of the borrowed amount. Customers are also charged a one-time fee of $6.00 for DMV lien registration and $2.00 for memorandum fees. A customer can redeem at the appropriate time or renew the pawn transaction by paying a fee less than the redemption amount.

1. Has a Pawn Transaction Been Created?

Essentially, the question is whether actual possession of the automobile is required or whether possession of the certificate of title is sufficient to create a pawn of the automobile. Defendant asserts that the pawn of titles to automobiles is a legitimate pawn transaction since it is not prohibited by statute. Specifically, Car Pawn claims that it retains constructive possession of the vehicles by actually possessing the certificate of title, thus completing the pledge and possession aspect of pawnbroking. In contrast, the Commonwealth asserts that delivery and possession of automotive titles does not create a proper pawn transaction and argues further that pawning demands actual possession of the pledged item. The court agrees.

Defendant believes that the ambiguity relating to the word possession used within the VPS should be construed to permit constructive possession because the pawnbroker statute is penal in nature. While it is true that this statute is penal and must be construed against the state, courts first must discover the legislative intent behind the law and give it effect. Turner v. Commonwealth, 226 Va. 456, 459, 309 S.E.2d 337 (1983), citing Tiller v. [414]*414Commonwealth, 193 Va. 418, 423, 69 S.E. 441 (1952). Plain meanings of words are preferred over the narrow constructions. Id.

Although regulations governing pawnbrokers do not define a “pawn,” the statutory definition of a pawnbroker requires “the pledge and possession of personal property” by the lender. Code of Virginia § 54.1-4000 (1950). Moreover, pledge is defined as “a deposit of personal effects, not to be taken back, but on payment of a certain sum, by express stipulation or on the course of trade.” Gilliat v. Lynch, 29 Va. (2 Leigh) 493, 500 (1831). Black’s Law Dictionary provides similar definitions. Black’s describes a “pawn” as “a bailment of goods to a creditor, as security for some debt or engagement.” Black’s Law Dictionary 1128 (6th ed. 1991). Clearly, the definitions permit delivery of the pawned item itself, yet there is no suggestion that delivery of and possession of an item’s title alone will suffice.

While defendant offers as authority the decision of the Supreme Court of Alabama which permitted a pawnbroker to take constructive possession of an automobile by taking a certificate of title, this Court finds that opinion unpersuasive. See Floyd v. Title Exchange and Pawn of Anniston, 620 So. 2d 576 (Ala. 1993).

Car Pawn argues by analogy that the General Assembly’s failure to expressly demand “actual possession” within the Pawnbroker Statute, as the Assembly had done in Va. Code Ann. §§ 20-125(8) and 55-3, allows a pawnbroker to take constructive possession. Another statute, § 8.7-102 relied upon by defendant was taken from the U.C.C. and adopted by the General Assembly. By adopting the Comments to that section, clarifying the type of possession necessary, the Assembly indicated a need to allow for constructive and actual possession in that instance. However, there is no indication from the General Assembly of a similar intent concerning the Virginia Pawnbroker Statute.

Moreover, the very nature of a pawn by “pledge and possession” compels the actual possession of the pawned item; otherwise, the General Assembly would have no need for the “and possession” language given the aforementioned definition of a pledge.

Holding title only is not the operation of a traditional pawn. Historically, items deposited with a pawnbroker remained in the possession of that pawnbroker. Pendleton v. American Title Brokers, 754 F. Supp. 860, 865 (S.D. Ala. 1991). Absent the automobile, vehicular titles are virtually worthless. For as defendants have proffered, it would be difficult to sell an automobile without the title. Conversely, it would be difficult to obtain any [415]*415value for a title when no vehicle is possessed. Essentially, there is no longer a pawn of property when that property is not retained. The transaction is simply a loan with property listed as collateral.

Furthermore, certificates of title normally are considered simply evidences of ownership. Black’s Law Dictionary 227 (6th ed. 1990). When security interests are recorded, titles also serve as written evidence of indebtedness. Credit Corp. v. Kaplan, 198 Va. 67, 73, 92 S.E.2d 359 (1956); see also Va. Code Ann. § 46.2-638.

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Related

Valley Acceptance Corp. v. Glasby
337 S.E.2d 291 (Supreme Court of Virginia, 1985)
Bowman v. Commonwealth
112 S.E.2d 887 (Supreme Court of Virginia, 1960)
Universal C. I. T. Credit Corp. v. Kaplan
92 S.E.2d 359 (Supreme Court of Virginia, 1956)
Turner v. Commonwealth
309 S.E.2d 337 (Supreme Court of Virginia, 1983)
Tiller v. Commonwealth
69 S.E.2d 441 (Supreme Court of Virginia, 1952)
Floyd v. Title Exchange and Pawn of Anniston, Inc.
620 So. 2d 576 (Supreme Court of Alabama, 1993)
Pendleton v. American Title Brokers, Inc.
754 F. Supp. 860 (S.D. Alabama, 1991)
Sweat v. Commonwealth
148 S.E. 774 (Supreme Court of Virginia, 1929)
Dyke v. Commonwealth
17 S.E.2d 366 (Supreme Court of Virginia, 1941)

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Bluebook (online)
37 Va. Cir. 412, 1995 Va. Cir. LEXIS 1124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-car-pawn-of-virginia-inc-vaccrichmondcty-1995.