Baldwin v. Castro County Feeders I, Ltd.

Castro County Feeders I, Ltd. (Castro County) (defendant) ran a feedlot operation in Texas in which it contracted to feed and provide vitamins, minerals, and medicine to cattle placed in its lots. Ryan Baldwin (plaintiff) owned and operated a business in Texas specializing in the purchase and sale of cattle. As part of the business, Baldwin often placed his cattle with Castro County. Castro County would feed the livestock for a period and then release the cattle to Baldwin for transport and sale in Kansas. Generally, the sale proceeds were made payable to Baldwin and Castro County to reimburse Castro County for the feed and related services provided to Baldwin’s cattle. Baldwin and Castro County entered into a Cattle Feeding Agreement (Agreement). In the Agreement, the definition of “collateral” generally included all Baldwin’s interest in farm products, limited to livestock, and the future sale of the same, as well as the livestock being “specifically located in Lot(s) # __________ at Castro County Feeders, I, Ltd., Hart, Castro County, Texas.” Baldwin sued Castro County in the South Dakota circuit court regarding Baldwin’s sale of 78 cattle owned by Baldwin in Wagner, South Dakota. The circuit court held that Castro County had a valid security interest in Baldwin’s cattle sold in Wagner and an enforceable security interest in the proceeds of the sale. Baldwin appealed to the South Dakota Supreme Court, arguing that the Agreement failed to sufficiently identify the cattle in question because the Agreement failed to specify the feedlots in which Baldwin’s cattle were located.