Ciejek v. Laird

A debtor conveyed to his creditor personal property upon which the creditor had perfected a security interest. We must determine whether that conveyance, by operation of law, destroyed the creditor’s lien position, leaving the property vulnerable to the claims of other creditors.

The facts are stipulated. David E. Laird, Jr., and his wife (collectively, Laird) owned a tract of unimproved land in Hanover County. On October 1, 1981, they entered into a written commercial lease, demising the land to Pocono Nurseries, Inc. (Pocono). Pocono occupied the land and conducted a nursery business…