## Facts

- Sellers conveyed a residence to buyers; after closing but before buyers took possession, sellers removed items from the house.
- Removed items included a plumbed and wired electric hot-water tank, custom-installed Venetian blinds, several hardwired light fixtures (including a chandelier), and three mirrors.
- Two large mirrors were fastened to walls using plywood backing and nails; removal damaged plaster and exposed differently colored paint, indicating long-term placement through at least one repainting.
- A third, smaller bathroom/powder-room mirror was not substantially affixed; it hung from a hook or rested on a bracket/support.
- Buyers demanded return of the removed items as fixtures conveyed with the realty; sellers refused, claiming they did not intend the items to become part of the property.

## Issues

1. Whether the removed wired light fixtures were fixtures that passed with the conveyance or personal property the sellers could remove.
2. Whether the three mirrors were fixtures that passed with the conveyance or personal property, given differences in their attachment.

## Decision

- The court modified the judgment for the buyers as to the disputed items.
- Wired light fixtures were fixtures “in law and in fact” and passed with the realty to the buyers.
- The two large wall mirrors attached with plywood backing and nails were fixtures and passed with the realty.
- The smaller bathroom/powder-room mirror, not substantially annexed to the structure, remained the sellers’ personal property.

## Legal Principles

- Fixture classification turns on (1) annexation to the realty, (2) adaptation to the use of the premises, and (3) intention shown by objective manifestations.
- Intention is determined from the nature and mode of attachment and the apparent purpose of the installation, not from undisclosed or “secret” intent to remove the item later.
- In a residential sale by an owner-occupier, items integrated into the structure or essential to a complete dwelling (e.g., hardwired lighting) are presumptively intended as permanent improvements and thus part of the realty.
- Substantial attachment and evidence of permanence (including removal damage and long-term integration) support fixture status; easily removable items without structural integration tend to remain personalty.

## Conclusion

The court held that hardwired light fixtures and two substantially attached wall mirrors were fixtures conveyed with the house, while a loosely hung or supported bathroom mirror was personal property that the sellers could remove.


Strain v. Green, 25 Wn.2d 692, 172 P.2d 216 (Wash. 1946)