Executive Financial Services, Inc. v. Garrison

Executive Financial Services, Inc. (EFS) appeals from the district court’s grant of summary judgment in favor of appellees in EFS’s suit for a deficiency judgment after *418repossession and sale of secured collateral. EFS contends the district court erred in holding that written notice is necessary under Missouri’s counterpart to Uniform Commercial Code § 9-504(3) as a prerequisite to a secured creditor’s right to a deficiency judgment. EFS also alleges that appellees waived their right to notice under the statute. Finding the district court’s construction of Missouri law to be reasonable, 535…