In re Grabowski

Bank of America (BoA) filed a 1998 financing statement in the Grabowskis' (plaintiffs) name broadly covering "all inventory, chattel paper, accounts, equipment, and general intangibles" and listing the address of their separately incorporated equipment business, while South Pointe Bank later filed a 2000 financing statement specifically itemizing particular farm equipment and listing the Grabowskis' home address; when the Grabowskis entered Chapter 11 bankruptcy, BoA and South Pointe both claimed priority over three specific pieces of equipment, with South Pointe arguing BoA's earlier statement was too general and improperly tied to the business address to effectively cover the disputed equipment.