Crane v. Citicorp National Services, Inc.

Toal, Justice:

The issues presented in this appeal are whether a co-obligator of a debt secured by consumer goods without title or right to possession of the goods can (1) recover in conversion against the creditor’s wrongful repossession under the South Carolina Consumer Protection Code, or (2) recover under the statutory penalty provided in the Uniform Commercial Code for the creditor’s failure to provide notice of the sale of the collateral.

FACTS

The Cranes purchased a mobile home on an installment sales contract and security agreement. The contract was immediately assigned to Citicorp by…