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Michigan Law Review

Common Law

1948

Change of possession

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Bailments-Delivery Of Possession-Liability Of Shopkeeper For Loss Of Article Left In Reception Room, Myron J. Nadler Dec 1948

Bailments-Delivery Of Possession-Liability Of Shopkeeper For Loss Of Article Left In Reception Room, Myron J. Nadler

Michigan Law Review

Without the knowledge of defendants, plaintiff hung her coat on a hook provided for wraps in the unattended reception room of defendants' beauty shop. Upon leaving, plaintiff returned to the reception room but was unable to find her coat. Judgment for its value was recovered in the lower court upon the theory that defendants were bailees of the coat and had been negligent in caring for it. Held, reversed. No bailment existed because there was no change of possession of the coat sufficient to constitute a delivery. Theobald v. Satterthwaite, (Wash.1948) 190P. (2d) 714.