Pearson v. Dodd
US COA, DC - 1969
Facts:
- Some folks entered P's office without his knowledge and photocopied various documents. The replaced the originals immediately.
- D was a journalist who used the documents to write a story on P.
- P sued D on the ground that the photocopying constituted conversion.
Procedural History:
- Trial court granted summary judgment to P, conversion valid.
- US COA DC reversed, conversion not valid.
Issues:
- Does the photocopying of documents which do not contain trade secrets, patents, or other sellable information constitute conversion?
Holding/Rule:
- The photocopying of documents which do not contain trade secrets, patents, or other sellable information does not constitute conversion.
Reasoning:
- Conversion requires a complete interference with the chattel and substantial deprivation of the possessory rights of the property.
- The copying was done at night and the documents were returned before the office opened the next day. P was never deprived of the documents.
- The information on the documents is not protected by any property right. They are not for sale or crucial for commercial reasons.
Dissent:
Notes:
