Goddard v. Winchell
86 Iowa 71 (1892)
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Rule of Law:
An object that falls from the sky and embeds itself in the soil through natural forces becomes part of that soil. As such, it is considered part of the real property and belongs to the owner of the land, not the finder.
Facts:
- John Goddard was the owner of a parcel of prairie land in Winnebago County, Iowa.
- Goddard had leased the grass privilege for the year 1890 to James Elickson.
- On May 2, 1890, a 66-pound meteorite, also known as an aerolite, fell from the sky and landed on Goddard's property.
- The meteorite buried itself three feet deep into the soil.
- The next day, Peter Hoagland, in the presence of the tenant Elickson, found the meteorite and dug it out of the ground.
- Hoagland claimed ownership of the meteorite on the basis that he had found it.
- On May 5, 1890, Hoagland sold the meteorite for $105 to H. Y. Winchell, who knew it was a meteorite that had fallen on the land.
Procedural Posture:
- John Goddard, the landowner, brought an action of replevin in the district court against H. Y. Winchell to recover possession of the meteorite.
- The district court, as the trial court, found in favor of the plaintiff, Goddard, concluding that the meteorite belonged to him as the owner of the land.
- The defendant, H. Y. Winchell, appealed the district court's judgment to the Supreme Court of Iowa.
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Issue:
Does a meteorite that falls from the sky and embeds itself into the earth become part of the real property, thereby belonging to the landowner?
Opinions:
Majority - Granger, J.
Yes, a meteorite that embeds itself in the earth is part of the real property and belongs to the landowner. The court reasoned that the principle of 'title by occupancy' or 'finders keepers' applies only to personal property that is lost or abandoned and found on the surface of the earth. This meteorite was not lost or abandoned; it was a natural deposit. The court likened the meteorite to soil, minerals, or boulders deposited by natural forces like wind, water, or glaciers through the doctrine of accretion. Because the meteorite was embedded in the soil and became a part of it through natural causes, it is properly considered part of the realty and belongs to the owner of that realty, Goddard.
Analysis:
This case establishes a key precedent for objects of value that become attached to land through natural, albeit unusual, means. It prioritizes the rights of landowners over the 'finders keepers' principle for objects that are integrated with the soil, rather than merely resting on its surface. By treating the meteorite as a form of 'accretion,' the court extended a traditional real property doctrine to a novel set of facts, solidifying the principle that land ownership includes things that become naturally affixed to it, regardless of their extraterrestrial origin. This decision limits the rights of finders and reinforces the landowner's claim to all constituent parts of their property.
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