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Stockman Bank of Montana v. Mon-Kota, Inc.

Montana Supreme Court
180 P.3d 1125 (2008)


Facts

Stockman Bank (creditor) loaned Hardy Farms (debtor) $5.5 million to finance growing agricultural crops. Stockman Bank took a security interest in Hardy Farms’ crops to secure the loan and properly perfected the security interest. AGSCO, Inc. (creditor) sold Hardy Farms agricultural chemicals. Hardy Farms financed the purchase through AGSCO’s financing affiliate, Capital Harvest. Capital Harvest secured the purchase by filing an agricultural lien against Hardy Farms’ crops under Montana’s agricultural lien statutory scheme. Stockman Bank’s interest was perfected before Capital Harvest’s lien, but the Montana statute granted priority to agricultural liens over other security interests in the encumbered crops. Hardy Farms defaulted. Capital Harvest alleged it had priority over Stockman Bank’s security interest under the Montana statute. Stockman Bank alleged Capital Harvest did not properly perfect its agricultural lien under the Uniform Commercial Code (UCC) and Stockman Bank therefore had priority. Both the district and appellate courts ruled in favor of Capital Harvest.

Rule of Law

Issue

Holding and Reasoning (Rice, J.)

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