In the Matter of Haley & Steele, Inc.
Massachusetts Superior Court
20 Mass L. Rptr. 204, 2005 WL 3489869 (2005)

- Written by Margot Parmenter, JD
Facts
Haley & Steele was an art dealership that accepted artwork from private owners on consignment. Under the dealership’s typical private-consignment agreement, Haley & Steele took possession of owners’ artworks—which, prior to consignment, had been employed for personal use—for specified periods of time and had the right to sell those artworks at agreed-upon prices. The consignment agreements also stated that the titles of consigned artworks remained with the consignors until they were paid. At some point in the early 2000s, Haley & Steele abruptly closed, at which time Century Bank Trust Co. seized many of the consigned artworks in an effort to recoup its interest as a secured creditor. The consignors asserted title to their artworks, and the court appointed a special master to adjudicate. In resolving the question of whether the bank was entitled to seize the consignors’ artworks, the special master examined whether the artworks were governed by the Uniform Commercial Code (UCC) or by common law.
Rule of Law
Issue
Holding and Reasoning (Van Gestel, J.)
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