State v. Bennett

246 P.3d 387, 150 Idaho 278, 73 U.C.C. Rep. Serv. 2d (West) 264, 2010 Ida. LEXIS 207
CourtIdaho Supreme Court
DecidedDecember 7, 2010
Docket36678
StatusPublished
Cited by8 cases

This text of 246 P.3d 387 (State v. Bennett) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bennett, 246 P.3d 387, 150 Idaho 278, 73 U.C.C. Rep. Serv. 2d (West) 264, 2010 Ida. LEXIS 207 (Idaho 2010).

Opinions

BURDICK, Justice.

Appellant William Lynn Bennett was convicted of grand theft and sentenced to eight years, with one-and-a-half years fixed. The court imposed a concurrent sentence of the same duration for a persistent violator enhancement. This case concerns the element of ownership in a charge of theft pursuant to I.C. § 18-2403(1) where a sale of goods is involved. We conclude that a seller of goods who has delivered the goods to the buyer, but has not yet been paid in full and does not have a security interest, is not an owner of the goods for the purposes of I.C. § 18-2403(1). We vacate.

I. FACTUAL AND PROCEDURAL BACKGROUND

This case arose out of Bennett’s purchase of a travel trailer from John LeFave. When Bennett moved out of state and took the trailer with him without making all the payments, LeFave reported the trailer missing and a criminal case ensued. At trial, the State established that Bennett entered into a verbal agreement with LeFave in October 2004 to purchase LeFave’s travel trailer.1 It was agreed that LeFave would take the trailer to the property of Carolynn Ellinger (an acquaintance of Bennett), where Bennett was staying, and that Bennett would make payments to LeFave until the full purchase price had been paid.

LeFave testified that the parties had not agreed to a payment structure but that he had told Bennett that he would take a down payment and they “would go from there and go to a finance company and get it straightened out.” LeFave testified that under the terms of the agreement, once Bennett finished paying for the trailer, Bennett would receive the title. LeFave testified that when [279]*279he delivered the trailer at Ellinger’s property he put a chain on it and a tongue and hitch lock system to keep it from being moved because Bennett did not have permission to move the trailer until it had been paid for in full. LeFave testified thát he told Bennett that if the trailer needed to be moved, Le-Fave would personally move it “so [he] would know where it was at all times.” However, Bennett testified that he was free to move the trailer and that it was not locked. Ellinger testified that the trailer was chained to the fence but was not locked.2

Bennett made at least one payment toward the purchase price,3 but then' LeFave learned that the trailer had been moved. Bennett stated that he informed LeFave that he would be moving and provided LeFave with his new address. LeFave testified that Bennett moved the trailer without permission or notice. After learning that the trailer had been moved, LeFave went to Ellinger’s property to confirm that it was missing and discovered that the lock had been removed and that part of the lock system had been left on the ground. However, Ellinger testified that she did not see a lock left behind when Bennett moved the trailer.

LeFave testified that Bennett called him a few months later to tell him he had moved the trailer to Washington. During that call, Bennett told LeFave to send him the title to the trailer and then Bennett would send Le-Fave $1000 but that if LeFave involved the police Bennett would burn the trailer. After contacting law enforcement, LeFave sent a certified letter to the address Bennett had given him on the phone, advising Bennett that LeFave was going to report the trailer as stolen and that if Bennett had any questions, he should contact the Boise Police Department. The letter was eventually returned as undelivered.4

In an effort to locate the trailer, LeFave drove to Washington to the address Bennett had given him. He discovered that both Bennett and the trailer were no longer at that location, and reported the theft of the trailer to law enforcement. At the time of trial, LeFave had received neither further payment nor a return of the trailer from Bennett.

Bennett was charged with grand theft under I.C. §§ 18-2403(1) and 18-2407(l)(b) and with being a persistent violator under I.C. § 19-2514. A jury found Bennett guilty of grand theft, and Bennett subsequently pled guilty to the persistent violator allegation. He filed a motion for judgment of acquittal, claiming that “[t]he inculpatory evidence presented on the material element of value was so insubstantial that jurors could not help but have a reasonable doubt as to the proof of that element.” The district court denied the motion, entered a judgment of conviction and imposed a unified eight-year sentence with one-and-a-half years determinate for the grand theft conviction. The court also imposed an identical sentence for the persistent violator enhancement to run concurrently. Although there was substantial conflicting testimony, the jury found that the trailer involved was valued at over $1000. The defense counsel at trial made a post-judgment motion to dismiss the case based upon the inadequacy of the valuation of the trailer. The district court denied the motion, and for purposes of this opinion this Court will not address that issue.

II. ANALYSIS

This decision hinges on the definition of “owner” in I.C. § 18-2402(6). Bennett was charged with a violation of I.C. § 18-2403(1). For Bennett to be guilty, LeFave must have been the “owner” of the trailer. Idaho Code § 18-2403(1) states: “A person steals property and commits theft when, with intent to deprive another of property or to appropriate the same to himself or to a third person, he wrongfully takes, obtains or withholds such property from an owner thereof.” (Empha[280]*280sis added). Idaho Code § 18-2402(6) defines “owner” as “any person who has a right to possession thereof superior to that of the taker, obtainer or withholder.” Thus, in this case, the State had the burden of proving that LeFave had possessory rights in the trailer which were superior to any possessory rights that Bennett had at the time of the alleged wrongful taking.

The Uniform Commercial Code (UCC) applies to transactions involving the sale of goods. I.C. § 28-2-102. Even though I.C. § 18-2402(6) defines “owner” for the purposes of the charged crime, that definition depends on the possessory rights of the persons involved, and the criminal code does not provide guidance on possessory rights. It is necessary to examine Article 2 of the UCC to determine the relative possessory rights of LeFave and Bennett.

LeFave parted with possession of the trailer by delivering it to Bennett. Upon Bennett’s breach of contract, LeFave did not regain superior possessory rights. First, under the UCC, an unpaid seller of goods does not have a remedy to retake the property. LeFave’s available remedy is to sue Bennett for the unpaid price pursuant to I.C. § 28-2-709(l)(a). Second, while LeFave may think that he was to retain title to the trailer until it was paid for in full, pursuant to I.C. § 28-2-401(1), “[a]ny retention or reservation by the seller of the title (property) in goods shipped or delivered to the buyer is limited in effect to a reservation of a security interest.” Although such a security interest would give the seller a superior possessory right in the property upon the buyer’s default, there is no legally enforceable security interest in this case.

A security interest arising under I.C. § 28-2-401 is subject to chapter 9, title 28, Idaho Code. I.C. § 28-9-110.

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Cite This Page — Counsel Stack

Bluebook (online)
246 P.3d 387, 150 Idaho 278, 73 U.C.C. Rep. Serv. 2d (West) 264, 2010 Ida. LEXIS 207, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bennett-idaho-2010.