Great Plains National Bank v. Mount and Cattle Consultants LLC, 2012COA66 (April 12, 2012)

This case could be the perfect bar exam question on secured transactions.  It has it all: perfection of security interests, purchase-money secured interests (PMSI), priority disputes, and 206 head of cattle. Smith, from OK, borrows money from Great Plains, secured by Smith’s cattle. Great Plains files a UCC statement in OK. Smith sells 206 cattle to Mount, a CO rancher financed by Cattle Consultants, who file a UCC statement against the cattle in CO. Everyone claims an interest the 206 cattle, but Great Plains wins. Its interest, perfected in OK, had priority because that is where the cattle were “produced” under the Federal Food Security Act.  So, Mount purchased subject to Great Plains’ lien. Consultants had a PMSI in the cattle, but it did not have priority because Consultants did not meet the requirements for a superior PMSI in livestock.  So, Great Plains had priority over Consultants.


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