Campins v. Capels

In the 1970s, John Capels (plaintiff) was awarded three national-championship rings by United States Auto Club (USAC). The USAC rings were typically awarded in particular automobile-racing categories. Capels received his rings following years of hard work as the chief mechanic or the owner of championship cars. The rings were made of gold, bore a synthetic-stone emblem, and were custom made for the recipient. In January 1981, the Capelses’ home was burglarized. The thief stole the three USAC rings and Mrs. Capels’s wedding band and sold these items to Julio Campins Jr. (defendant). Campins immediately melted the rings under circumstances in which he knew or should have known that the rings were stolen. Thereafter, Campins refused to make restitution to the Capelses. The Capelses sued Campins for criminal mischief under state law, which provided for treble damages to the victims of theft. Capels testified regarding the lack of market for the USAC rings, that he had purchased a duplicate ring for $349 in 1977, that the cost of gold had doubled since 1979, and that he estimated the USAC rings to be worth between $700 and $1,000, finally settling on a value of $750 per ring. Capels described the personal significance of the rings to him and that he would not have sold them. The trial court ruled in the Capelses’ favor, valuing the wedding band at its recently appraised value of $700 and the three USAC rings at $1,000 each. Campins appealed, primarily disputing the valuation of the three USAC rings.