Poggi v. Scott


Two thieves, Bernaradini and Ricci, arranged to “purchase” broken barrels from a landlord which they knew to be valuable. The landlord sold his tenant’s barrels to them for a small sum. The tenant sued for the value of the barrels (about $51,000 in 2020 dollars).

Questions of law

What role does intent play in conversion? If a defendant believed the property of no value, is he to be held responsible for its full value?


The court found that the only requirement for conversion to lie was the intent to commit the tortious act, not any particular special knowledge or wrongful mental state. “Conceding all that may be argued as to the absence of improper motives, he sold barrels that did not belong to him and which did with their contents belong to the plaintiff.”

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