## Facts

- John Goddard owned a tract of prairie land in Iowa.
- A 66-pound meteorite fell onto Goddard’s land and embedded itself about three feet into the soil.
- The next day, a neighbor, Hoagland, accompanied by Goddard’s tenant, entered the land, dug up the meteorite, and removed it.
- Hoagland sold the meteorite to H. V. Winchell for about $101.
- Winchell knew the meteorite had fallen on land south of Hoagland’s property, i.e., on Goddard’s land.
- Goddard sued Winchell in replevin to recover the meteorite; the trial court found the meteorite became part of the soil and entered judgment for Goddard.

## Issues

1. Whether a meteorite that falls and becomes embedded several feet into the ground becomes part of the realty so that title vests in the landowner.
2. Whether the “title by occupancy” rule for unowned movables allows the first finder to take title to an embedded meteorite and transfer good title to a purchaser.

## Decision

- The Iowa Supreme Court affirmed.
- The meteorite became part of the soil upon impact and embedding and therefore belonged to Goddard as landowner.
- Hoagland acquired no title by discovery and removal, and Winchell acquired no better title than Hoagland had.

## Legal Principles

- Under accession principles (*quidquid plantatur solo, solo cedit*), a thing permanently annexed to land becomes part of the real property and belongs to the landowner.
- The occupancy rule for unowned movables applies to loose personal property found on the surface; it does not apply to objects naturally deposited and embedded in another’s land.
- A purchaser from a wrongful taker generally receives no title when the seller had none, even if the object was previously unowned before becoming part of the land.

## Conclusion

An embedded meteorite is treated as a natural deposit that becomes part of the land where it falls; title vests in the landowner immediately, and neither a finder nor a buyer from the finder can claim ownership against the landowner.


Goddard v. Winchell, 86 Iowa 71, 52 N.W. 1124 (Iowa 1892)