Hughes purchased a new Lincoln Continental automobile from Al Greene, Inc., an authorized new car dealership. On the day of the sale, Hughes made a cash down payment and signed a purchase contract and an application for the title certifi cate. The understanding was that Hughes would take immediate possession of the car and return in a few days for new-car preparation and the installation of a CB radio. On the way home from the dealer, Hughes wrecked the car. The certifi cate of title had not yet been issued by the state. The buyer, Hughes, claimed that title had not yet passed, since the title certifi cate had not yet been issued. Who must bear the loss? [ Hughes v. Al Greene, Inc., 418 N.E.2d 1355 (Ohio).]