First National Bank, Cortez v. First Interstate Bank, Riverton, N.A.

URBIGKIT, Justice.

This appeal presents a UCC and FAA airplane security-interest-priority conflict between two lenders, and raises a question of the validity of antecedent-debt inclusion in document clauses variously labeled dragnet or anaconda. We reverse the trial court’s finding that the first recorded security interest should be accorded priority.

The rule here established is that an anaconda or dragnet clause, as a matter of notice to subsequent parties in interest or claimants to the encumbered asset, is valid in the absence of actual knowledge only if the additionally included existent…