A judgment for the plaintiff in an action of trover shall not operate to transfer the title to the property converted unless and until such judgment has been satisfied.
§ 8.01-219.Effect of judgment in trover.
Chapter 3. Actions · Article 21. Miscellaneous Provisions · Last amended 1977 · Last verified July 16, 2026
In one sentenceSection 8.01-219 provides that winning a trover judgment for the value of converted property does not transfer ownership of that property to the defendant until the plaintiff collects payment on the judgment.
Full Text of § 8.01-219
Plain-English Summary
An action of trover lets an owner sue someone who wrongfully took control of, used, or disposed of the owner’s personal property — a conversion — and recover the property’s value in money damages. This section addresses a narrow but important timing question: once the plaintiff wins that judgment, who owns the property?
The answer is that title does not shift automatically. Even though a trover verdict measures damages by the property’s value — treating the case, in effect, as if the plaintiff sold the property to the defendant for that amount — Virginia does not let the defendant treat the judgment alone as a completed purchase. Ownership passes to the defendant only once the judgment has been satisfied, meaning paid. Until then, the plaintiff who obtained the judgment remains the property’s owner, even though a court has also fixed its money value.
Frequently Asked Questions
What is an action of trover?
Trover is a common-law action for conversion, letting an owner recover the value of personal property that someone else wrongfully took, used, or disposed of as their own.
If I win a trover judgment, does the defendant now own the property?
Not until the judgment is satisfied. Section 8.01-219 provides that title passes only when the judgment is paid in full, not merely when it is entered.
What happens if the defendant never pays the judgment?
Title never transfers under this section. The plaintiff remains the legal owner of the property even though the defendant has been ordered to pay its value, and the plaintiff keeps whatever other collection remedies are available.
Why does it matter whether title has passed?
Because it determines who legally owns the property for other purposes — for example, if the property is later recovered or a third party deals with it, ownership turns on whether the judgment was paid.
Does partial payment transfer partial title?
The statute speaks to satisfaction of the judgment — full payment or discharge — so a partial payment does not satisfy the judgment, and title stays with the plaintiff until the judgment is fully satisfied.
Amendment History
Code 1950, § 8-648; 1977, c. 617.
Source & verification. Section text and amendment history are
reproduced verbatim from the Code of Virginia, published by the
Code of Virginia, Virginia Division of Legislative Automated Systems. Last verified July 16, 2026.
· Official source
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