Pankratz Implement Co. v. Citizens National Bank
Supreme Court of Kansas
130 P.3d 57 (2006)
Relevant factsFree
Pankratz's financing statement misspelled debtor Rodger House's name as "Roger," while a later lender, Citizens National Bank, filed using House's correct name; after House's bankruptcy, Pankratz sought priority over CNB's competing security interest, and the court of appeals had found the misspelling seriously misleading because a correct-name search would not surface Pankratz's filing.
IssueFree
Whether minor errors in a debtor's name that do not fall under the safe harbor provision of Uniform Commercial Code § 9-506(c) are seriously misleading such that they render a financing statement ineffective.
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