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Meyhoeffer v. Wallace
Louisiana Court of Appeal
792 So. 2d 851 (2001)
Facts
David Wallace (defendant) was a farmer who leased 530 acres of farmland from the land’s owner, Dr. Klaus Meyhoeffer (plaintiff). Under the terms of the lease, Wallace was to pay Meyhoeffer either $32,000 or one-fifth of the proceeds of the sale of the crops grown on the land, whichever was greater, every year for the term of the lease. Meyhoeffer recorded the lease in the conveyance records of the parish but failed to record it in the state’s agricultural central registry. In 1998, Wallace obtained a loan from Winnsboro State Bank & Trust Company (the bank) (defendant) to finance his farming. The bank took a lien in the proceeds of Wallace’s crops and properly recorded it in the agricultural central registry. Wallace was unable to pay either his obligation to the bank or the rent he owed to Meyhoeffer in 1998. The bank took possession of all of the proceeds from that year’s crop and applied them to Wallace’s outstanding debt. Meyhoeffer sued Wallace and the bank, alleging that his rights as the lessor were superior to the bank’s lien. The trial court concluded that because the bank had perfected its interest by recording in the central registry as required under state law, which Meyhoeffer had failed to do, the bank’s interest outranked Meyhoeffer’s interest. Meyhoeffer appealed.
Rule of Law
Issue
Holding and Reasoning (Peatross, J.)
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