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"The controversy whether the title to a converted chattel vests in a defendant by simple judgment, or only after the satisfaction of the judgment, is, therefore, but another battle of the knights over the gold and silver shield. Under some circumstances the title changes by the judgment alone; in other cases satisfaction is necessary to produce that result."

Such was the conclusion of Ames on the mooted question whether, in an action for conversion, the mere entry of a judgment for the value of the converted chattel, or the payment of the judgment, passed the title of the chattel to the converter. The early cases stated that title passed by the judgment.2 It has long been the fashion, however, to say that, not the judgment, but only satisfaction of it passes the title.3 Thus the court in Decker v. Milwaukee Cold Storage Co. (1920,Wis.) 180 N. W.256, states that, by the "great weight of authority", it is only the satisfaction of the judgment which, by law, divests the original owner of his title. Much of the difficulty and much, though not all, of the conflict in the cases comes from the use of the uncertain and indefinite term "title" to express varying legal situations for which a closer definition is desirable. "Title" is a concept of much agility. Generally, when it appears, we find in it a tendency to flit here and there with a suddenness which is surprising, and hence we should not be surprised to find it possessing these characteristics in the situation under discussion. The confusion comes from the fact that title is applied to an aggregate--a "bundle"--of legal relations, and we find the term used indiscriminately to indicate a bundle of various sizes.

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Judgment or Satisfaction as Passing Title, 30 Yale Law Journal 742 (1921)

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