D came onto P's land, cut down his trees (worth $25), and turned the trees into barrel hoops (worth $800).
D claimed that he did so in good faith, believing that he had permission from the owner of the land to chop the trees down.
P sued D for the barrel hoops.
Procedural History:
Lower court found for P, awarded P the barrel hoops.
Issues:
If a person, acting in good faith, takes the property of another, adds his own labor, and creates something much more valuable, does the original owner have the right to the transformed property?
Holding/Rule:
If a person, acting in good faith, takes the property of another, adds his own labor, and creates something much more valuable, the original owner has no right to the transformed property, only to the reasonable cost of the property before the transformation.
Reasoning:
Giving the original property owner the transformed property when D was involuntarily a wrong-doer would over-compensate the original property owner.
There must be some limit to the right to follow and reclaim materials which have undergone a process of manufacture.
There is a distinction between possession in bad faith (owner entitled to goods whether transformed or not) and possession in good faith (owner only entitled if not substantially changed, value added).
The fact that the value of the materials increased 100 fold is of more importance than any chemical or physical change which is not expensive to the party changing it or adds anything to the value.
D's labor gave the timber in its present condition nearly all its value. Equity requires that the value added stays with D.
