Charles E. Covey v. State Bank of Toulon

HAMILTON, Circuit Judge.

In these appeals we consider whether a secured lender can use parol evidence against a bankruptcy to save a security agreement from a mistaken description of the debt to be secured. The security agreement here said that the collateral secured a promissory note made on a given date. The date was a mistake. The borrower had executed a promissory note but two days after the stated date. This is the sort of mistake that can be corrected as between' the original parties to the loan by reforming the instrument based on par-ol evidence.

We have previously held, however, that…