Fitzgerald v. American General Finance, Inc. (In re PSALTO)
United States Bankruptcy Court for the District of Idaho
225 B.R. 753 (1998)
Facts
Before March 7, 1997, Matt Psalto, an Idaho resident, bought a snowmobile in Wyoming. No certificate of title was ever issued for the snowmobile. On March 7, 1997, Psalto obtained a loan from American General Finance, Inc. (AGF) (defendant) and pledged the snowmobile as security for the loan. AGF filed a Uniform Commercial Code (UCC) financing statement with the Idaho Secretary of State. Psalto subsequently filed for bankruptcy. Fitzgerald (plaintiff), the bankruptcy trustee, initiated an action seeking to avoid AGF’s security interest in the snowmobile pursuant to Fitzgerald’s hypothetical-lien-creditor status under the Bankruptcy Code. Specifically, Fitzgerald argued that AGF failed to properly perfect its interest under Idaho law.
Rule of Law
Issue
Holding and Reasoning (Pappas, C.J.)
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