Haslem v. Lockwood

• "Haslem" = a farm owner and employer = plaintiff
• In Stamford, Connecticut in April 1869, Haslem directed 2 employees to rake abandoned horse manure into heaps that had accumulated in a public street. His intention was to carry it away the next day.
• Lockwood, who had no knowledge of the Haslem’s actions, found the nicely-packed & ready heaps of manure & hauled them off to his own land.
• (Horse manure was valued for providing farm lands with nutrients.)
• Haslem demanded payment for the heaps of manure.
• Lockwood refused to pay up.

• Haslem filed a trover lawsuit against Lockwood.
• Lockwood won in the trial court.
• Lockwood won again in the Court of Common Pleas.

Does a person who adds value to abandoned property become its owner such that he may leave it for a reasonable time before returning to collect it?

• Lockwood argued that he hauled away the manure heaps because they were abandoned.
• Haslem argued that the manure heaps were his personal property.

Yes; someone who adds value to abandoned property (by assembling the manure into heaps) acquires legal possession of it that can withstand his leaving it un-attended for a reasonable time (such as 1 day).

Reversed