Rock Rapids State Bank v. Gray

McCORMICK, Justice.

When repossessed collateral “threatens to decline speedily in value,” a secured party is excused from giving the debtor notice of an intended sale. Iowa Code § 554.9504(3) (1983). After selling collateral provided by defendants James V. Gray and Ruth K. Gray without notice, plaintiff Rock Rapids State Bank brought the present action for deficiency judgment against them. In excusing the bank’s failure to give notice, the trial court found the exception was applicable. We reverse because we hold that the court’s finding is not supported by substantial evidence and that the…