Delphi Auto. Sys., Inc. v. Capital Cmty.

Certified Tool and Manufacturing Corporation purchased a Komatsu press and agreed in a “lease” to pay Capital Community Economic/Industrial Development Corporation monthly payments for the press. Certified Tool later obtained a loan from Delphi Automotive Systems, LLC and granted Delphi an interest in its property under a security agreement. Delphi perfected its security interest. After Certified Tool defaulted on the promissory note and security agreement, Delphi filed a declaratory judgment action asserting that its perfected security interest in the Komatsu press was superior to the unperfected security interest claimed by Capital Community. The court of appeals concluded that Capital Community’s security interest in the Komatsu press was not subject to the provisions of Article 9 of the state’s Uniform Commercial Code. The Supreme Court reversed, holding that there was no basis for excusing Capital Community’s failure to comply with Article 9, and therefore, Delphi’s perfected security interest in the Komatsu press prevailed over Capital Community’s unperfected security interest. View "Delphi Auto. Sys., Inc. v. Capital Cmty." on Justia Law