Defendant purchased and went into possession of land in 1944 at which time a logging donkey was upon the land. The donkey had been on defendant's land without having been moved or used since 1942. From 1944 to 1952 defendant made numerous inquiries as to the ownership of the donkey without success. Through various conveyances, beginning in 1946, and without any transfer of possession, plaintiff acquired title to the donkey in 1952. In May 1952, in order to further develop his land, defendant sold the donkey. In a suit by plaintiff for conversion of the donkey, the lower court ruled that the action was barred in 1945 by the three-year statute of limitations. On appeal, held, affirmed. Plaintiff's cause of action accrued when the donkey came to rest on defendant's land, since the title of the true owner was then reduced to a right of immediate possession or to a cause of action in the event immediate possession was denied. Jones v. Jacobson, (Wash. 1954) 273 P. (2d) 979.
Irving L. Halpern,
Limitations of Actions - Conversion,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol53/iss8/15