What is the test for determining whether goods have reached their ultimate destination?

In Cabeen v. Campbell, 30 Penn. St. 254, Strong, J., applies as the test the inquiry whether the goods have reached their place of ultimate destination, understood as such between the seller and buyer. Even where there is a middleman he enunciates the rule to be, that, if in the hands of the middleman they require new orders to put them again in motion and give them another substantive destination, if without such new orders they must continue stationary, the delivery is complete, and the lien of the vendor has expired.

In Covell v. Hitchcock 23 Wend. 612, Walworth C., remarked: “The time during which the right exists, therefore, is during the whole period of the transit from the vendor to the purchaser, or the place of ultimate destination as designated to the vendor by the buyer; and this transit continues as long as the goods remain in the possession of the middleman, whether he be the carrier either by land or by water, or the keeper of a warehouse or place of deposit connected with the transmission and delivery of the goods.”