Transfer to a dead person cannot and does not transfer title. In light of that legal conclusion and the other relevant facts (neither policy defined "owned," the stolen truck was the insured vehicle, Michael had paid the required premiums, and Michael retained exclusive possession of the truck and continued to use it after he "transferred" title to his father), the appellate court determined that a triable issue of material fact exists as to whether he was entitled to coverage. 

The California Appellate Court's opinion was published on April 24, 2001 as Liberty Mutual Fire Ins. Co. v. McKenzie .

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