As I understand this common law action, the remedy developed in the law to redress the injury to the personal property of an owner. In the case of the action of trespass vi et armis, the wrongful act is immediately injurious to the personal property of another and is accompanied by a degree of force: e. g. shooting a man's dogs or taking from the value of any of his personal property or worsening its condition. In the instance by the trespass action on the case, the act itself is indifferent, and the injury is *consequential* and without a breach of the peace. For example, the spray from painting the garage drifts across the property line and coats the neighbor's car. In both of these trespass actions, the plaintiff shall recover damages in proportion to the injury which he proves his property sustained. Hope this helps. Marilyn Symonds To subscribe, change options, or unsubscribe, please see the instructions at http://listlva.lib.va.us/archives/va-hist.html