Meeks v. Mercedes Benz Credit Corp.
United States Court of Appeals for the Eighth Circuit
257 F.3d 843 (2001)
Billy Stinnett bought a truck on credit in Texas from Texarkana Truck Center, which assigned its security interest to Mercedes-Benz Credit Corporation (defendant); Stinnett listed his Arkansas home address in the security agreement but registered the truck in Oklahoma using a business address obtained solely for that purpose, and Oklahoma issued a title reflecting MBCC's lien even though Stinnett actually operated the truck out of Arkansas. After Stinnett's bankruptcy, the trustee, William S. Meeks (plaintiff), sued to avoid MBCC's lien, arguing the title should have been issued in Arkansas instead, and both the bankruptcy court and district court ruled for MBCC.
Whether, under Article 9 of the Uniform Commercial Code, a lien noted on a vehicle's certificate of title is valid if the certificate was issued by a state other than the one where the vehicle should have been registered.