Conversion Action for Renewable Energy Credits


On an issue of first impression, the Court of Appeals of Georgia concluded that renewable energy credits are considered “specific intangible property” that is subject to a claim of conversion. Conversion is a claim that another person exercises ownership or control over personal property contrary to the plaintiff’s rights.

The Court compared the RECs to other property deemed to qualify for a conversion claim, such as social media accounts, teaching materials on a laptop, and bitcoin.

Since the RECs were intangible property, the plaintiff could assert a claim of conversion if the defendant exercised ownership or control over them, such as registering them with REC registries.

Sterling Planet, Inc. v. GRP Holdco, LLC, — Ga. App. –, A24A1281, 2025 WL 761103 (Mar. 11, 2025)

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