Western Farm Service, Inc. v. Olsen

Key Bank National Association (Key Bank) challenges a Court of Appeals decision reversing the trial court’s grant of summary judgment in its claim for conversion against J.R. Simplot Co. (Simplot). Key Bank, which held a security interest in potato crops purchased by Simplot, claims that Simplot converted proceeds when it *647failed to designate Key Bank as a copayee on a check issued to the seller as a hauling allowance. We hold that the hauling allowance constitutes proceeds and reinstate the judgment of the trial court.

FACTS

Lynn Olsen is a potato and onion farmer, farming approximately 4,000…