Citizens Savings Bank v. Miller

NEUMAN, Justice.

This dispute focuses on conflicting rights of secured creditors who each claim priority in fifteen head of cattle owned by defendants Dale and Arlene Miller. Plaintiff Citizens Savings Bank of Hawkeye, Iowa (“Hawk-eye”) asserts priority based on a purchase money security interest (“PMSI”). Defendant First National Bank of Sumner, Iowa (“Sumner”) contests the validity of Hawk-eye’s PMSI and rests its claim on prior perfection of its security interest. The district court, ruling on cross-motions for summary judgment, held that Hawkeye’s inability to identify the proceeds of its…