In re Filtercorp, Inc.
United States Court of Appeals for the Ninth Circuit
163 F.3d 570 (1998)
Paulman (defendant) drafted a promissory note granting himself a security interest in Filtercorp's (debtor) accounts receivable and inventory, attaching a specific list of Filtercorp's existing inventory to the note; after Filtercorp filed bankruptcy, it argued Paulman's security interest did not extend to accounts receivable and inventory acquired after the agreement's execution, and the bankruptcy court granted Filtercorp summary judgment on that basis, finding no security interest in after-acquired property absent an express provision covering it, a ruling the bankruptcy appellate panel affirmed. Paulman appealed.
Whether a security agreement that grants an interest in inventory or accounts receivable includes after-acquired inventory or accounts receivable, respectively, absent evidence of contrary intent.