Huntington National Bank v. Elkins

The narrow issue presented for our review is whether price alone is determinative of “commercial reasonableness.” For the reasons which follow we answer this query in the negative and reverse the court of appeals.

The right of a secured party to dispose of collateral after a debtor’s default is codified at R.C. 1309.47 (U.C.C. 9-504). R.C. 1309.47(C) requires that “* * * every aspect of the disposition including the method, manner, time, place, and terms must be commercially reasonable.” Price alone is not determinative of “commercial reasonableness” in the sale of collateral after a debtor’s…