Kenyon v. Abel
In Kenyon v. Abel, 2001 WY 135, 36 P. 3d 1161 (Wyo. 2001), the Court said conversion occurs when a person treats another's property as his own, denying to the true owner the benefits and rights of ownership.
This statement arguably suggests that title to the property must remain in the party alleging conversion for the claim to survive.
However, the Court also said in Kenyon that a converter's title to stolen property is void, arguably suggesting that conversion can occur even where legal title to the property is transferred to the converter.