Part 6- Credit, Chapter 29: Security Interests in Personal Property, Doc 5 | Indiana University Bloomington - Edubirdie

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Indiana University Bloomington
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Financial and Managerial Accounting: Information for Decisions - John J. Wild
Academic year:

2024
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471

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1
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bratrochanter

In Yeadon Fabric Domes, Inc. v. Maine Sports Complex, LLC, the court examined the priority of security interests in fixtures. Yeadon provided an inflatable fabric dome and associated equipment for Maine Sports Complex (MSC) and initially filed a financing statement with the Secretary of State, which was not a proper fixture filing. Later, Yeadon filed a fixture filing in the county registry but after other creditors, Kiser and Harriman, had perfected their interests through mechanic’s liens. MSC defaulted on payments to all parties, leading to a dispute over lien priority. The court ruled that for Yeadon to have priority under UCC Section 9-334(4), it needed to file a fixture filing within 20 days of the dome becoming a fixture, which it failed to do. Additionally, under Section 9-334(5)(a), Yeadon would only have priority if its fixture filing was completed before the competing liens from Kiser and Harriman were recorded, which did not occur. Key Points: 1. Fixture Filing Requirement: Under UCC rules, a security interest in fixtures must be perfected with a fixture filing in the appropriate registry to establish priority. 2. Timing of Filing: Fixture filings must be timely (e.g., within 20 days after goods become fixtures) to ensure priority over conflicting interests. 3. Implications for Lien Priority: In this case, Yeadon’s later fixture filing could not take precedence over the earlier liens, affirming the importance of prompt and correct filing to protect security interests in fixtures. This case highlights the need for secured parties to accurately file and time fixture filings to avoid losing priority to mechanic’s liens or other encumbrances.

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