Alaska State Bank v. General Insurance Co. of America

579 P.2d 1362
CourtAlaska Supreme Court
DecidedJune 16, 1978
Docket2638, 2713
StatusPublished
Cited by22 cases

This text of 579 P.2d 1362 (Alaska State Bank v. General Insurance Co. of America) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alaska State Bank v. General Insurance Co. of America, 579 P.2d 1362 (Ala. 1978).

Opinions

OPINION

Before BOOCHEVER, C. J., and RABI-NOWITZ, CONNOR, ERWIN and BURKE, JJ.

BURKE, Justice.

The dispute in this case centers on whether a bonding company’s interest in earned progress payments qualifies as a security interest subject to the filing and priority provisions of the Alaska Uniform Commercial Code.1

The events leading to this controversy began when Gilman’s Construction, Inc., formerly Gilman’s Excavating, Inc., contracted with the State of Alaska to construct Project No. F-046-l(16) and LSF-046-1(4), commonly known as the Tok Cutoff Project. The contract was executed on September 18,1970. Needing payment and performance bonds, Gilman’s approached appellee General Insurance Company of America (hereinafter the bonding company). The bonding company agreed to write the necessary bonds and acquired collateral against possible losses by requiring Gil-man’s to execute an instrument entitled “General Agreement of Indemnity for Contractors.” Among other things, this agreement, which was executed in July of 1970, assigned to the bonding company Gilman’s right to monies earned under bonded contracts.

The agreement contained a'provision for perfection by the bonding company, under the Uniform Commercial Code, of the alleged security interest granted to it by Gil-man’s.

[The parties] [ajgree that this agreement may at any time be completed and filed by [the bonding company] in such a manner that it will qualify as a financing statement under the applicable provisions of any statute of any state which has adopted the Uniform Commercial Code, and that [the bonding company] may add such schedules to this agreement, describing specific items of security covered hereunder as shall be necessary under such statutes.

The bonding company, however, chose not to file the agreement or any other document as a financing statement.2 Subsequently, the bank, in financing Gilman’s operations, acquired security for its loans by inducing Gilman’s to execute on July 23, 1970 a security agreement assigning to the bank, inter alia, all of Gilman’s contract rights. The bank attempted to perfect this security interest by filing a financing statement on August 5, 1970 with the Alaska Department of Administration, as required by the Uniform Commercial Code.

[1364]*1364Gilman’s commenced work on the Tok Cutoff job. On or about September 8,1971, however, Gilman Watts, the principal of Gilman’s, presented himself at the offices of the bonding company in Seattle and acknowledged that he could not complete his contract. Gilman’s had at that tim.e fully earned a progress payment.of $169,895.00, but the money had not, as yet, been disbursed by the State. Thereafter, representatives of the bonding company attended a meeting in Anchorage with officers of the bank. The meeting resulted in the establishment of a trust account at the bank for use by the bonding company in connection with the Tok Cutoff job.

In mid-September the State was informed by telegram and letter from the bonding company and Gilman, respectively, that Gilman’s was in default; had suspended work on the project; was unable to complete the contract with the State; and was unable to pay its laborers, materialmen and suppliers. The State was further informed that the bonding company was completing the project. Nine days later, on September 29, the State issued a check in the amount of $169,895.00 payable to the bonding company. The check was sent to the bank where it was deposited in the trust account without signature and collected. On October 11, 1971, a cashier’s check in the amount of $169,895.00 was sent by the bank to the bonding company. When subsequent investigation revealed that the bonding company had failed to perfect its alleged security interest in the earned progress payment, the bank commenced this action.

The respective positions of the parties can be summarized as follows:

The bonding company argues that when a contractor defaults and a bonding company steps in to complete the job and pay laborers and materialmen, it is subrogated to the rights of the owner, the contractor, the laborers, and the materialmen. Since the owner could have used funds still in its hands to complete the job, there would have been no sums available for the contractor and, therefore, for the contractor’s secured creditor who stands in the contractor’s shoes. Under this view the bonding company has first rights to the progress payment, although it may have been fully earned by the contractor’s prior performance.

The bank argues that progress payments are contract rights and that the bonding company’s subrogation theory merely purports to impose on them a hidden lien. The bank urges that both it and the bonding company had the power to take advantage of Article 9 of the Uniform Commercial Code and perfect their respective security interests. Under this view, the bank had prior rights since it utilized the U.C.C. while the bonding company did not.

Judge Eben Lewis, in a Memorandum Decision handed down on February 10, 1975, accepted the bonding company’s view. He utilized as his standard the “Fifth Circuit Doctrine” which holds that only when the bank’s money can be shown to have gone into a project to earn an undisbursed progress payment does the bank have a superior equitable claim since it relieved the bonding company of a burden that it would otherwise have had to bear.

Judgment was entered for the bonding company on cross motions for summary judgment when Judge Lewis found that the bank had failed to establish that its money was traceable to the Tok Cutoff job.

The first major issue that confronts this court is whether the lower court erred in finding that the unperfected assignment by Gilman’s to its bonding company, of earned progress payments, was a security interest governed by the Uniform Commercial Code, as adopted in Alaska.

The bank urges the court that this “classic dispute” between bank and bonding company should be resolved under the Uniform Commercial Code. It cites various cases3 decided by this court in an attempt [1365]*1365to buttress its argument that the adoption of the Uniform Commercial Code reflects a legislative judgment to apply U.C.C. principles even where the U.C.C. by its terms is not applicable.4 Even though the U.C.C. does not specifically deal with the case at bar, the bank argues that the policy of the U.C.C. is to draw distinctions based on functional rather than formal lines. According to the bank, both it and the bonding company initially had an interest in a “contract right;” that is, “a right to payment under a contract not yet earned by performance and not evidenced by an instrument or chattel paper.”5 It should be noted that the Indemnity Agreement assigns to the bonding company:

Monies due or to become due Contractor on any Contract, including all monies earned or unearned which are unpaid at the time of notification by [the bonding company] to the Obligee of [the bonding company’s] rights hereunder.

It follows, the bank stresses, that the bonding company has by assignment intended to enter a transaction 6 creating an interest in personal property that secures payment or performance of an obligation7 subject to8 the filing9

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Alaska State Bank v. General Insurance Co. of America
579 P.2d 1362 (Alaska Supreme Court, 1978)

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Bluebook (online)
579 P.2d 1362, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alaska-state-bank-v-general-insurance-co-of-america-alaska-1978.