General Motors Acceptance Corp. v. Berry

The life of the doctrine of the trust receipt has been characterized as a short but adventurous one. 36 Harv. Law Rev. 229.

Professor Williston in the second edition of his work on Sales, published in 1924, says (p. 797): “It seems probable that if the practice-of permitting validity to unrecorded liens by way of trust receipts is, to continue, limits must be fixed either judicially or by statute to the-kinds of transactions in which such receipts may be used. At present, the question has not been fully considered how far public policy should permit such a secret title to prevail over general…