## Facts

- West Coast Airlines owned two aircraft engines (“A” and “B”) and possessed all FAA-required logbooks and maintenance records for them.
- West Coast sealed each engine in a heavy steel storage container (“engine can”) and stored the cans near its hangar; engine A was ready for future use and engine B was stored after a mechanical failure.
- West Coast routinely sold unusable scrap metal to a scrap dealer, Junk Traders, and instructed it to remove numerous empty scrap cans stored along a fence line.
- By mistake, the two sealed engine cans containing engines A and B were taken with the scrap cans, though West Coast did not intend to sell the engines as scrap.
- Over a year later, Miner’s Aircraft’s president learned the cans likely contained aircraft engines, inspected them at the junkyard, and purchased them from the scrap dealer.
- Miner’s Aircraft later sold one engine to Robert Clark.
- After discovering the mistake, West Coast demanded return of both engines and filed a replevin action to recover them (or their value).

## Issues

1. Whether the engines were included in West Coast’s scrap-sale contract with Junk Traders such that Junk Traders could convey title.
2. Whether West Coast abandoned the engines by placing the sealed cans near the fence and failing to discover their removal promptly.
3. Whether Miner’s Aircraft (and a downstream purchaser) acquired good title by purchasing from a scrap dealer.
4. Whether substantial evidence supported the trial court’s challenged findings of fact.

## Decision

- The Washington Supreme Court affirmed judgment for West Coast.
- The court held the engines were not part of the scrap-sale agreement; Junk Traders had no title to convey.
- The court held West Coast did not abandon the engines and retained the right to exclusive possession.
- The court upheld the trial court’s fact findings as supported by substantial evidence and declined to reweigh conflicting evidence.
- The replevin remedy ordering return of the engines (or their value) was affirmed.

## Legal Principles

- Appellate courts do not substitute their view of disputed facts for the trial court’s where findings are supported by substantial evidence.
- A valid transfer of title requires that the goods be within the parties’ mutual intent to sell; mistaken inclusion of property in a shipment for sale does not, by itself, transfer title.
- Abandonment requires an act plus intent to relinquish ownership; negligence or delay in discovering a mistaken disposition is insufficient without intent.
- A purchaser generally cannot obtain better title than the seller possesses absent an applicable statutory exception; a scrap dealer without title cannot pass good title to a buyer.

## Conclusion

Because West Coast never intended to sell the engines as scrap and did not abandon them, the scrap dealer lacked title, and Miner’s Aircraft and a subsequent purchaser could not acquire valid title through the junkyard purchase; the owner was entitled to replevin and the trial court’s supported fact findings were binding on appeal.


West Coast Airlines, Inc. v. Miner's Aircraft & Engine Serv., Inc., 66 Wash. 2d 513, 403 P.2d 833 (Wash. 1965)