Rite Credit Tire Co. v. A. B. Williams Auto Sales Co.

10 Ohio Law. Abs. 428, 1931 Ohio Misc. LEXIS 1199
CourtCity of Dayton Municipal Court
DecidedAugust 12, 1931
DocketNo. 72249
StatusPublished
Cited by1 cases

This text of 10 Ohio Law. Abs. 428 (Rite Credit Tire Co. v. A. B. Williams Auto Sales Co.) is published on Counsel Stack Legal Research, covering City of Dayton Municipal Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rite Credit Tire Co. v. A. B. Williams Auto Sales Co., 10 Ohio Law. Abs. 428, 1931 Ohio Misc. LEXIS 1199 (Ohio Super. Ct. 1931).

Opinion

MARTIN, J.

Whether plaintiff or defendant was the owner and entitled to the possession of said tires and tubes at the times same were taken into possession and sold by defendant as a part of Campbell’s car, depends upon the legal effect of the ultimate facts and the terms of the instruments above recited.

In Ohio it is well established that the legal title to mortgaged chattel property is in the mortgagee.

Robinson, Jr., v Fitch, 26 Oh St 659 at page 663:

“1. A chattel mortgage in the usual form conveys (to the mortgagee the property mortgaged, and he thereby becomes the general owner of it, and in the absence of a reservation of the right of possession in the mortgagor, he is entilted to the immediate possession of it. If there is such a reservation in favor of the mortgagor, such reservation only affects the possession according to the terms of the reservation, the title to the property remaining in the meantime in the mortgagee, who becomes entitled to the immediate possession on breach of the condition.”

This statement of the law has been followed or approved in more than a score of Ohio decisions.

It is equally well established that a chattel mortgage does not include and cover after-acquired property which does not become a part of the original property by accession as against lien creditors of the mortgagor with or without notice of the mortgage, unless the mortgagee reduce such after-acquired property to possession before the mortgage or lien of the creditor attaches. A mortgage with an after-acquired property clause does, however, impose a continuing, executory obligation on the mortgagor to give the mortgagee a lien on after-acquired property.

Nertzorg v National Supply Company, 18 C. D. 112.

Inasmuch as the undisputed facts in this case show that the tires and tubes were not reduced to possession by defendant before' plaintiff’s mortgages were filed, it follows that the provisions of defendant’s mortgage hereinbefore recited were not operative in and of themselves to perfect title in defendant to the tires.

The entire question is whether or not the addition of tires and tubes to Campbell’s car under the circumstances hereinbefore recited amounted to an accession?

A number of different considerations have controlled the courts in determining whether there has been an accession, chief among which are:

1. Change of species or entire transformation from one thing to another.
2. Identity, or the retention of the original form so that it can be traced, identified, severed and reclaimed as an entity and entirety without injury to itself or the property to which it is attached.
3. Relative value, in which the property having the greater value is considered the principal thing.
4. Intention of the parties where other things are equivocal.
5. Actual or presumed knowledge of the vendor and mortgagee of the thing added with reference to the method of attachment and use of the added part, and the existence of a general mortgage to another on the principal thing.
6. The status of the property with reference to the title or liens thereon at the time it is acquired by the mortgagor and attached to the principal thing.

Considerations 1, 3 and 4 are not, in the opinion of the court applicable to the facts of this case.

The leading Ohio cases discuss the matter of accession chiefly from the standpoint of the notice or knowledge, actual 0£ constructive, which the vendor, lien claimant or mortgagee of the added part or accessory receives or is presumed to receive of a properly filed chattel mortgage on the [430]*430principal thing, and likewise from the standpoint of the notice or knowledge which the vendor, lien claimant or mortgagee of the accessory receives with reference to its attachment to the principal thing and the authorization or procuring of, or consent to or partaking in, such attachment.

The much discussed case of Securities Company v Orlow, 107 Oh St 583, is authority for the' proposition that a repairman claiming a mechanic’s lien against an automobile for accessory parts and labor added thereto, was charged with constructive notice of a chattel mortgage on file against the car and by reason thereof his lien was inferior and subject to the lien of the chattel mortgage. The court further held that the facts of the case and the terms of the mortgage did not imply consent on the part of the mortgagee to the repair of the car or authority on the part of the mortgagor to have the same repaired, though the terms of the mortgage required the mortgagor to have the same repaired in that the mortgagor was bound to keep .the car in first-class condition and order at his own expense.

The case of Continental Finance Co. v Gold Seal Tire Co., 6 O L A 26, decided by the Court of Appeals of this district, holds that mortgaged tires, placed, without the knowledge of the mortgagee, upon a mortgaged automobile may be held by the mortgagee of the tires against the mortgagee of the automobile in an action of replevin. In this case the tire mortgagee failed to properly file its chattel mortgage before the plaintiff, mortgagee of the car, repossessed the car with the tires thereon. While the car was in the possession of plaintiff, defendant removed and possessed itself of the tires, The court in its opinion stressed the lack of knowledge on the part of the tire company that the mortgagor was going to place or had placed the tires on a mortgaged car, and held in effect that the tires, in the absence of knowledge by defendant that they were being attached to a mortgaged car, did not become accessions thereto. It does not appear from the court’s decision whether or not the mortgage assigned to plaintiff contained an after-acquired property clause, but, assuming that it did not, the taking possession of the car by plaintiff had no significance or effect in investing plaintiff with title to or a lien on the tires. The court further held that plaintiff could not attack the validity of defendant’s chattel mortgage after defendant had reduced the tires to possession for the reason that plaintiff did not stand in the position of a creditor who had obtained lawful possession of the tires by some legal process. In its opinion, the court says:

“It will be noted in this case • that the Tire Company sold the tires in controversy to Johnson who was then the owner of the mortgaged automobile, but it does not appear that he tire company authorized consented to or even knew, that the tires were to be placed upon the mortgaged automobile. This case, therefore differs from the case of Securities Company v Orlow, 107 Oh St 583, where the repairs in question were actually placed by the artisan upon the automobile. The artisan there was, as the court held, charged with constructive knowledge of the mortgage upon the automobile upon which the repairs were made. We have examined the case of Blackwood Tire & Vulcanizing Co. v Auto Storage Co., 133 Tenn 515, and Purnell v Fooks, 122 Atl. 901. In both cases the tires were placed upon the car by consent and with the knowledge of the party who afterward claimed ownership of the tires.

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Related

Mechanic v. Schaeffer
23 Ohio Law. Abs. 129 (Ohio Court of Appeals, 1937)

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Bluebook (online)
10 Ohio Law. Abs. 428, 1931 Ohio Misc. LEXIS 1199, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rite-credit-tire-co-v-a-b-williams-auto-sales-co-ohmunictdayton-1931.