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Washington Supreme Court - 66 Wash. 2d. 513, 66 Wash. 2d 513
tl;dr:
The parties entered into an agreement for scrap metal removal, but then the junk removers accidentally took two engines along with the scrap metal.Video Summary
Case Summary
In West Coast Airlines, Inc. v. Miner's Aircraft & Engine Service, Inc. (1965), a significant contract law case, the Supreme Court of Washington looked at whether a scrap metal buyer could obtain ownership of two jet engines mistakenly included in their purchase from the seller.
The lawsuit concerned whether the seller's mistake and lack of intent to sell affected the sale's validity. West Coast Airlines (plaintiff) had accidentally placed two valuable jet engines among scrap metal containers that they sold to Junk Traders. Miner's Aircraft (defendant) bought the containers containing the engines from Junk Traders for only $125, knowing they weren't mere scrap metal and that Junk Traders didn't have the needed paperwork to sell aircraft parts. Miner's Aircraft later sold one engine to Robert Clark (defendant).
West Coast sought the engines' return, and the trial court ruled in their favor. Miner's Aircraft appealed, but the Washington Supreme Court also sided with West Coast. The court reasoned that since West Coast didn't intend to sell the engines and no fraud or negligence occurred on their part, they still had ownership. Junk Traders couldn't pass on ownership due to inadequate payment and lack of good faith or due care.
This case is essential as it demonstrates how consensual theory of sale can protect a seller and shows how courts address mistake, good faith, and adequate consideration in contract law.
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West Coast Airlines filed a replevin action to recover two aircraft engines from Miner's Aircraft & Engine Service and Robert Clark. Miner's Aircraft appealed the judgment citing 27 errors, but the court found that the trial court's findings of fact were supported by the evidence. West Coast purchased the engines with all necessary documents and was entitled to exclusive possession of the engines and their records. The engines were stored in sealed "cans" along a fence near the hangar and were salvaged by Junk Traders. Mr. Miner convinced Junk Traders that the two engines belonging to West Coast Airlines were only worth scrap metal prices and purchased them for $125 without requesting the required FAA documents. Miner's Aircraft sold engine "B" to Clark without the necessary accompanying documents, but failed to deliver it due to subsequent events. The trial court ordered Miner's Aircraft to return the two engines to West Coast and awarded Miner's Aircraft a judgment against Junk Traders for $100. Clark was awarded a judgment against Miner's Aircraft for the return of his seven cylinder lapping machines and $100 for expenses.
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