He could not have passed valid title even to a good faith purchaser. Id.; Gurley v. Phoenix Ins. Co., 233 Miss. 58, 61, 101 So.2d 101, 102 (1958). Textile Supplies, therefore, retained title to the carpet even after Garrett obtained it from Couch. "[E]ven though the sale of the property is made to a bona fide purchaser for value, if it is stolen property, the person from whom it was stolen is not divested of his title."

One who steals property cannot pass good title to it, even to a bona fide purchaser. See Western Sur. Co. v. Redding, 626 P.2d 437, 439 (Utah 1981); Gurley v. Phoenix Ins. Co., 233 Miss. 58, 101 So.2d 101 (1958); Allstate Ins. Co. v. Estes, 345 So.2d 265 (Miss. 1977). Cf. Butler v. Farmers Ins. Co., 126 Ariz. 371, 616 P.2d 46, 47 (1980) (bona fide purchaser of stolen property has a title defeasible only by the rightful owner).

40 Am.Jur. 747, Payment § 49; 36 Am.Jur. 460, Money § 6. The rule governing title to stolen cash aad negotiable instruments is clearly contrary to that governing title to stolen chattels: 42 Am. Jur. 227, Property § 51; Gurley v. Phoenix Ins. Co., 233 Miss. 58, 101 So.2d 101, 71 A.L.R.2d 221 (1958). See United States v. Barnard, 72 F. Supp. 531 (W.D. Tenn. 1947), in which the court held that a rare $20 gold piece was a chattel and not subject to the "cash" exception.

See R. Brown, The Law of Personal Property § 67. One who steals property cannot pass good title to it, even to a bona fide purchaser. See Western Sur. Co. v. Redding, 626 P.2d 437, 439 (Utah 1981); Gurley v. Phoenix Ins. Co., 101 So.2d 101 (Miss. 1958); Allstate Ins. Co. v. Estes, 345 So.2d 265 (Miss. 1977).

One who steals property cannot pass good title to it, even to a bona fide purchaser. See Western Sur. Co. v. Redding, 626 P.2d 437, 439 (Utah 1981); Gurley v. Phoenix Ins. Co., 233 Miss. 58, 101 So.2d 101 (1958); Allstate Ins. Co. v. Estes, 345 So.2d 265 (Miss. 1977).

We have more than once said this of stolen automobiles, Allstate Insurance Company v. Estes, 345 So.2d 265, 266 (Miss. 1977); Gurley v. The Phoenix Insurance Co., 233 Miss. 58, 61, 101 So.2d 101, 102 (1958), viz., A purchaser can take only those rights which his transferer has in the subject goods; a thief has neither title nor power to convey such.

Napavale, Inc. v. United National Indemnity Co., 169 Cal.App.2d 119, 336 P.2d 984 (1959); Gordon v. Gulf American Fire Casualty Co., 113 Ga. App. 755, 149 S.E.2d 725 (1966); Hessen v. Iowa Automobile Mutual Insurance Co., 195 Iowa 141, 190 N.W. 150 (1922). See also Southern Farmers Mutual Insurance Co. v. Motor Finance Co., 215 Ark. 601, 222 S.W.2d 981 (1949) (innocent purchaser of stolen property not included within sole ownership clause); Gurley v. Phoenix Insurance Co., 233 Miss. 58, 101 So.2d 101 (1958) (innocent purchaser of stolen property not included within sole ownership clause). Other jurisdictions, however, cite principles of real property or public policy in finding the existence of the requisite relationship.

We also note that this rule is not inconsistent with prior cases holding that the purchaser of a stolen vehicle does not obtain good title, since there the transferor did not obtain the vehicle by "delivery under a transaction of purchase." Gurley v. Phoenix Ins. Co., 233 Miss. 58, 101 So.2d 101 (1958) [stolen auto]; Allstate Ins. Co. v. Estes, 345 So.2d 265 (Miss. 1977) [stolen auto and forged bill of sale].

The dictate of Section 75-2-403 is clear. Regardless of the number of transactions, one cannot remove himself from the confines of the rule: A purchaser can take only those rights which his transferor has in the subject goods; a thief has neither title nor the power to convey such. Gurley v. The Phoenix Ins. Co., 233 Miss. 58, 101 So.2d 101 (1958). Accordingly, title remained in Allstate and the circuit court order granting possession to Estes was erroneous.

"It is the law in this State that a bona fide purchaser of a stolen automobile acquires no title and no insurable interest therein and, therefore, may not recover under a theft insurance policy when the vehicle is subsequently stolen from him." The cases of Gurley v. Phoenix Insurance Company, 233 Miss. 58, 101 So.2d 101, 71 A.L.A.2d 221; Napavale, Inc. v. United National Indemnity Company, 169 Cal.App.2d 119, 336 P.2d 984, and Hessen v. Iowa Automobile Mutual Insurance Company, 195 Iowa 141, 190 N.W. 150, support this proposition of law. The trial court rendered judgment (as stated above) for the defendant insurance company on the ground that, although the plaintiff had an insurable interest in the vehicle, the insurance policy did not cover that particular interest.