First National Bank in Creston v. Francis

The effect of the majority opinion is to exalt form over substance. While acknowledging that the purpose of the section 554.-9402(1) description is to aid purchasers and third-party creditors in identifying the secured crops, J. White & R. Summers, Handbook of the Law Under the Uniform Commercial Code § 23-16 at 964 (2d ed. 1980), and that the Iowa cases and Code Comments place “inquiry” responsibility on purchasers and third-party creditors, the majority absolves the purchaser here of any responsibility. Finding the description not to signal a need for further inquiry, the majority ignores…