Conversion Is Strict Liability Tort for Which Apportionment Is Available—Ninth Circuit

The Ninth U.S. Circuit Court of Appeals held yesterday that conversion under California law is a strict liability tort for which apportionment of fault with other tortfeasors is available, reviving a third-party complaint by defendants who were accused of keeping stock certificates that were wrongly transferred to them after they paused a deal without paying and who asserted equitable indemnity claims against the agents purportedly responsible for the transfer.