Richmond v. F-40 Restoration, LLC (2020)

Facts and holding

An antique-car restorer sold his client’s Pierce Arrow without authority, obtaining a New Jersey title in his own name. After successive resales and refunds, a downstream business held the car and certificate. The court granted the owner’s partial summary-judgment motion for replevin. Full court-hosted opinion, pp. 1–10.

The § 42a-2-403 entrustment defense failed because the restorer did not regularly sell antique cars. The voidable-title defense also failed: the owner had delivered the car for services, not intending the restorer to acquire ownership. Embezzlement gave the restorer void title that good-faith downstream purchase did not cure. The court did not decide whether the defendants otherwise qualified as good-faith purchasers. Full opinion, pp. 11–17.

Limits

This was an unauthorized private sale, not adjudication of a compliant § 49-61 auction or the four other service-lien statutes. The decided count was replevin, not the separately pleaded conversion count. See connecticut, motor-vehicles.

Full primary opinion retrieved October 17, 2026; no comprehensive later-treatment certification.

Bounded final review (2026-10-18)

Full ruling retrieved 2026-10-18 from the District Court’s public document link. Comprehensive later treatment remains needs_verification; no citator certification is made.

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