State v. Dix, 465 P.3d 1090

Dix purchased over $1,000 of goods (mostly new power tools) from Grainger on an open line of credit for purported businesses and picked them up on multiple occasions between Nov 2015 and Nov 2016.
On the same days he picked up the goods, Dix pawned them at Vista Pawn (and some at First National Pawn); pawn slips required the pawner to assert ownership.
The State charged Dix with grand theft (obtaining goods on credit without intent to pay) and burglary (entering a pawnshop to pawn goods alleged to be stolen); Dix was convicted, placed on probation, and ordered to pay restitution.
Dix argued at trial that under the UCC and State v. Bennett he obtained title and superior possessory rights when Grainger delivered the goods, so Grainger was not the “owner” for theft purposes; the trial court denied Rule 29 motions and jury instructions on UCC-based defenses.
The Idaho Supreme Court granted review and reversed both convictions, holding the UCC controlled: title and superior possessory rights passed on delivery and Vista Pawn, a good-faith purchaser, received good title.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Grainger was the “owner” with superior possessory rights when Dix obtained the goods (grand theft)	Dix acquired goods by fraud and intended not to pay; theft occurred upon possession	Under the UCC (and Bennett), title passed to Dix on delivery and Grainger did not retain an enforceable security interest, so Grainger lacked superior possessory rights	Reversed: State failed to prove Grainger was owner; title and superior possessory rights passed to Dix on delivery
Whether pawning the goods constituted burglary (victim: Vista Pawn or Grainger)	Pawning goods obtained by fraud is burglary/receipt of stolen goods; Grainger is victim of the theft/burglary	Dix had voidable title that could transfer good title to a good-faith purchaser; Vista Pawn was a good-faith purchaser for value	Reversed: Vista Pawn received good title under UCC §2-403; no burglary as to Vista Pawn, and Grainger was not entitled to pawn proceeds

State v. Bennett, 150 Idaho 278, 246 P.3d 387 (2010) (UCC governs possessory-right analysis for theft involving sales of goods)
State v. Jesser, 95 Idaho 43, 501 P.2d 727 (1972) (title passes on delivery absent contract conditions that prevent passage)
W. Idaho Prod. Credit Ass'n v. Simplot Feed Lots, Inc., 106 Idaho 260, 678 P.2d 52 (1984) (voidable title can transfer good title to a good-faith purchaser for value)
Tempur-Pedic Int'l, Inc. v. Waste to Charity, Inc., 483 F. Supp. 2d 766 (W.D. Ark. 2007) (articulating policy justifications for protecting good-faith purchasers and finality in commerce)