1.    Defense and recapture involves two things
i.    possession by the owner
ii.     a purely wrongful taking
Kirby v. Foster  $50 deducted from P’s pay, so P kept $50 from payroll. D’s held him in struggle to get money back. Issue: Were D’s justified in use of force to get money back? No. They could defend with necessary force only. And only if the P had no claim or right, even if the claim was wrong.