Dayka & Hackett, LLC v. Del Monte Fresh Produce N.A., Inc.
Arizona Court of Appeals
269 P.3d 709 (2012)
Mexican grape growers De la Rosa and Ramos gave D&H (plaintiff) a security interest in their 2007 and future crop proceeds, which D&H perfected by filing in the District of Columbia because Mexico lacked an established recording system for security interests at the time; after defaulting on that debt, the growers gave a similar security interest in their 2008 crop to Del Monte (defendant), who registered its interest in Mexico without knowing of D&H's prior interest. D&H sued to enforce its interest against the 2008 crop proceeds Del Monte had collected; the trial court granted D&H summary judgment, and Del Monte appealed.
Whether, under the Uniform Commercial Code, the law of the debtor's jurisdiction governs perfection if the debtor is located in a jurisdiction with a system for recording security interests for priority.