First of America Bank v. Thompson

The instant deficiency action was brought by plaintiff, the assignee bank under a motor vehicle retail installment sales contract, against defendant, a co-buyer for the purchaser, following repossession and sale of the vehicle. The question is whether the applicable limitation period is four years as set forth in § 2-725 of the Uniform Commercial Code (UCC), MCL 440.2725(1); MSA 19.2725(1), or she years as generally applicable to contract claims, MCL 600.5807(8); MSA 27A.5807(8). We conclude that a deficiency action, although arising from both a sale of goods and a secured transaction,…