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Agrifund v. Heartland Co-Op

436 F. Supp. 3d 1230 (2020)

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Agrifund v. Heartland Co-Op

United States District Court for the Southern District of Iowa
436 F. Supp. 3d 1230 (2020)

Facts

Agrifund, LLC (plaintiff) loaned approximately $4.2 million to farmers Anthony and Mary Salter. As security for this loan, Agrifund had a perfected lien on the Salters’ 2017 crops. In November 2017, the Salters sold some of their crops to Bunge Elevator for $600,000. The Salters used the sale proceeds to fund a $328,124.46 check that they gave to Heartland Co-Op (defendant) to pay a farm-supply debt. At that time, Heartland knew that Agrifund had an active lien on the Salters’ crops. However, the Salters did not tell Heartland where they obtained the money for the check, and Heartland did not ask. Agrifund demanded that Heartland turn over the $328,124.46, but Heartland refused. Agrifund sued Heartland in federal district court for conversion, alleging that Heartland had taken wrongful possession of money that belonged to Agrifund. Heartland asserted an affirmative defense that it was a holder in due course of the Salters’ check. Both parties moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Pratt, J.)

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