Also known as: meuble · movables · biens meubles
Written by attorneys — see sources below.
Tangible personal property or chattels. The classification of a thing as a meuble determines whether choice-of-law rules for movables or immovables govern interests in the thing.
Praxis Leasing leased semi-trailers titled in State K to Horizon Freight. The trailers were stored and operated from a hub in State L where creditors held judgments. When creditors sought to levy, the court weighed contacts across States J, K, and L to identify the state with the most significant relationship to the trailers and the parties.
Atlas Capital held secured interests in artwork and precious metals stored in a State B vault. After the storage company entered receivership, local creditors challenged priority. The court applied the law of the state with the most significant relationship to the collateral and the parties rather than automatically selecting the location or a party's domicile.
A decedent domiciled in Louisiana left movables to children born outside marriage. The court applied Louisiana rules limiting such donations of movables to the amount necessary for sustenance, treating the classification of the assets as meubles as dispositive of the transfer's validity.
Lou Bertha Patterson gave birth to Rita Vincent on March 15, 1962, in Calcasieu Parish, Louisiana. On May 10, 1962, Patterson and Ezra Vincent jointly executed a Louisiana State Board of Health form before a notary public acknowledging that Vincent was the natural father of the child. This acknowledgment occurred under Louisiana procedures but did not alter the child's status for purposes of intestate succession. Ezra Vincent died intestate on September 16, 1968, in Rapides Parish, Louisiana, leaving substantial property within the state but no will to direct its distribution. Lou Bertha Labine, as guardian and tutrix of Rita Vincent, petitioned the state court for the appointment of an administrator for Vincent's estate, a declaration that Rita Vincent was the sole heir, and an order directing support and maintenance payments for the child. In the alternative, the petition sought a declaration of entitlement to $150 per month in support under Louisiana law. The administrator of the succession answered the petition by claiming that Vincent's relatives were entitled to the entire estate. The trial court ruled that the father's collateral relations took the property and dismissed the petition with costs. It also denied the support claim in light of Social Security payments of $60 per month and Veterans Administration payments of $40 per month available to the child. The Louisiana Court of Appeal, Third Circuit, affirmed the judgment, and the Supreme Court of Louisiana denied a petition for writ of certiorari. The child's guardian appealed to the United States Supreme Court, which noted probable jurisdiction.
View caseA man domiciled in China with two wives died in California leaving movable property there. The court recognized the marriages under Chinese law and applied the law of the decedent's domicile to distribute the movables, treating the assets as meubles governed by domicile-based succession rules.
Dalip Singh Bir, a native of India, died intestate in San Joaquin County on April 18, 1945. Respondent Florence Boyes was appointed and qualified as administratrix of his estate. On April 4, 1947, two women named Harnam Kaur and Jiwi, both residents of India, joined in a petition to determine heirship. They alleged that they were the legally wedded wives of the deceased, having lawfully married him in the Punjab over 50 years ago while all parties were domiciled in Punjab Province, British India, according to the law and manner of the Jat community. Their petition further alleged that the residue of the estate consists of approximately $1,450 in cash and that in India petitioners would be entitled to share equally in the estate. The record before the court contains a stipulation signed by counsel for the respective parties. The stipulation states that the petition was presented to the court as a joint petition requesting solely a judgment of an undivided one-half interest to each petitioner as the legal widows of Dalip Singh Bir. The trial court found that decedent, while domiciled in the Punjab Province of India, there married and was possessed of two wives, the petitioners above named, and that petitioners were legal spouses of decedent under the laws of the Punjab Province of India. It further found that thereafter decedent emigrated to the United States and established residence in California, and that the money belonging to his estate was community property. Neither of said marriages had been dissolved prior to decedent’s death, but no satisfactory proof was introduced as to which of the marriages was first performed. Upon these findings of fact the trial court entered an order continuing the matter awaiting proof as to which of the marriages was first performed and which of the two petitioners was the initial wife of decedent. From that order the two wives have appealed.
View caseClassification as a meuble directs the forum to the local law of the state with the most significant relationship to the thing and the parties under the principles of section 6, without incorporating that state's choice-of-law rules in most transfer disputes between the parties.
The reference becomes the full law when the issue involves the effect of a transfer on third parties or succession to interests in movables, requiring the forum to reach the same result a court of the selected state would reach.
Parties enter property transactions with forethought and often consult counsel, so their expectations of legal consequences deserve protection absent strong countervailing considerations.
The factors include the policies of interested states, the parties' justified expectations, certainty and predictability of result, implementation of basic property policies, and needs of judicial administration.