In re SemCrude LP
United States Court of Appeals for the Third Circuit
864 F.3d 280 (2017)
- Written by Eric Miller, JD
Facts
SemCrude LP (debtor), a provider of midstream oil services, purchased oil on credit from thousands of producers across multiple states. SemCrude then sold the oil to various downstream purchasers, including J. Aron & Company (J. Aron) and BP Oil Supply Company (BP) (defendants). SemCrude and its affiliates were registered in Delaware and Oklahoma. SemCrude filed for Chapter 11 bankruptcy, which interrupted the regular flow of payments—both from SemCrude to the upstream producers and from the downstream producers to SemCrude. Producers based in Texas and Kansas (plaintiffs) filed adversary proceedings against J. Aron and BP. The Texas and Kansas producers had not filed financing statements to perfect their interests in the oil sold to SemCrude and, ultimately, J. Aron and BP. However, the Texas and Kansas producers argued that nonuniform amendments their states had made to the Uniform Commercial Code (UCC) automatically gave them perfected security interests in the oil. The bankruptcy court granted summary judgment in favor of J. Aron and BP, holding that they had purchased the oil from SemCrude as buyers for value, free of any lien. The Texas and Kansas producers appealed to the United States Court of Appeals for the Third Circuit.
Rule of Law
Issue
Holding and Reasoning (Ambro, J.)
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