In the case of Collins v. Lewis 111 Conn. 299, 149 A. 668 (Conn. 1930), Collins was a sheriff who attached a herd of cows from someone named Kinne.  Lewis was the rightful owner of the cows and that Kinne was holding them under a conditional-sale contract.  Collins returned the cows but Kinne refused to take them back. Lewis wouldn't take the cows back either, so Collins had to feed and stable the cows.  He attempted to charge Lewis for the upkeep costs for the cows for 38 days until Lewis sold them to someone else who took them away.  The Court found for Collins and said that the fact that Lewis benefited from Collins' storage of the cows, combined with Collins' letter to Lewis telling him that he was going to charge him for feeding the cows established that there was an implied contract formed.