Tuesday, December 31, 2013

O’Keeffe v. Snyder case brief

O’Keeffe v. Snyder case brief summary
416 A.2d 862 (1980)

CASE SYNOPSIS
Defendant art gallery owner appealed a grant of summary judgment rendered by the Superior Court, Appellate Division (New Jersey) in favor of plaintiff artist in her action for replevin under N.J. Stat. Ann. § 2A:14-1 to recover three paintings that were allegedly stolen years earlier from another gallery.

CASE FACTS
Plaintiff artist sought to recover three paintings from defendant's gallery that were she allegedly owned and which were stolen from another gallery. Defendant asserted he was a purchaser for value, had taken title of the paintings by adverse possession, and that the action for replevin was barred by the statute of limitations period.

HOLDING
The court held that the lower court erred in granting summary judgment to plaintiff by concluding that the paintings were stolen and that defendant had not proven the elements of adverse possession.

DISCUSSION

  • The court noted that defendant contested the theft and had conceded it only for purposes of having his adverse possession claim decided. 
  • The court decided that the factual disputes warranted a remand. 
  • The court indicated that it could not determine who had title on the limited record before it, but proceeded to resolve questions of law that would become relevant on remand. 
  • ]The discovery rule applied in determining when the statute of limitations began to run in the action for replevin.

CONCLUSION
Court reversed grant of summary judgment in plaintiff's favor and remanded back for trial because it was error to accept one of two conflicting versions of material fact when defendant conceded the fact only for purposes of enabling the court to determine his motion for summary judgment.


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