Mislaid items are those intentionally parted with and unintentionally forgotten. Mislaid items are generally awarded to landowner. Treasure trove items are intentionally hidden with intention to return to reclaim. Treasure trove is money, gold, silver or bullion hidden in the earth, and, in modern cases, hidden in places above ground as well. Treasure trove generally awarded tin finder, occasionally, even if finder is a trespasser.
Some courts favor landowner when item is embedded in soil.