In Re Firth

363 F. Supp. 369, 180 U.S.P.Q. (BNA) 306, 13 U.C.C. Rep. Serv. (West) 343, 1973 U.S. Dist. LEXIS 12015
CourtDistrict Court, M.D. Georgia
DecidedSeptember 6, 1973
Docket20829
StatusPublished
Cited by19 cases

This text of 363 F. Supp. 369 (In Re Firth) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Firth, 363 F. Supp. 369, 180 U.S.P.Q. (BNA) 306, 13 U.C.C. Rep. Serv. (West) 343, 1973 U.S. Dist. LEXIS 12015 (M.D. Ga. 1973).

Opinion

OWENS, District Judge:

James A. Firth, an individual doing business under the unregistered trade name of National Photocopy Equipment Company, on June 2, 1972, filed a bankruptcy petition under § 322 of the Bankruptcy Act, 11 U.S.C.A. § 722. Pursuant to § 376 of the Act, 11 U.S.C.A. § 776, he was adjudged a bankrupt on December 14, 1972. The First National Bank & Trust Company in Macon on January 31, 1973, as an alleged secured creditor, filed a reclamation petition seeking the return of certain items of personal property. Because the bank’s security instruments including mainly but not limited to its Uniform Commercial Code financing statements and the Georgia motor vehicle certificate of title showed the name of the debtor and owner as National Photocopy Equipment Co., an unregistered trade name, and not as James A. Firth, the trustee contended that the bank’s alleged security interests were not valid. The Referee’s order sustained the trustee’s contentions, and it is that order that is before this court for review. It poses two questions:

(a) Is a Uniform Commercial Code financing statement that shows the name of the debtor only in his unregistered trade name form legally sufficient to create a security interest?
(b) Is a valid security interest created by the issuance of a Georgia motor vehicle certificate of title which shows the name of the owner in his unregistered trade name form?

I. The Financing Statements The financing statements filed by the bank are identical in every material aspect. 1 A form was employed for filing purposes, the upper left hand corner of which is entitled:

“1 Debtor(s) (Last Name First) and address(es)”

Each statement bears the name of the debtor as “National Photocopy Equipment Co.” In the space provided for the *371 debtor’s signature, each financing statement is executed as follows:

“National Photocopy Equipment Co.
“By: /s/ James A. Firth_
“Signature(s) of Debtor(s)”

The name as shown is the unregistered trade name of Firth, who is the sole owner and operator of the business. The statements were filed with the Clerk, Superior Court, Bibb County, Georgia, prior to June 2, 1972, and naturally were indexed according to the unregistered trade name only.

Georgia Code Annotated § 109A-9— 402, provides, inter alia, that:

“(1) A financing statement is sufficient if it is signed by the debtor and the secured party, gives an address of the secured party from which information concerning the security interest may be obtained, gives a mailing address of the debtor and contains a statement indicating the types, or describing the items, of collateral. ft
* * # * *
“(5) A financing statement substantially complying with the requirements of this section is effective even though it contains minor errors which are not seriously misleading.”

In arguing that its financing statements met the formal requirements of Ga.Code Ann. § 109A-9 — 402(1), the bank relies on several introductory provisions of the Uniform Commercial Code,* the Georgia statute on transactions conducted by firms doing business under unregistered trade names, 2 3 and National Cash Register Co. v. Sikes, 94 Ga.App. 391, 94 S.E. 2d 782 (1956), a pre-code case. Its reliance is misplaced.

Although there are no appellate decisions in Georgia concerning the use of an unregistered trade name on a financing statement, the precise issue has been properly decided elsewhere. In In re Leichter, 471 F.2d 785 (2d Cir. 1972), the bankrupt executed both a conditional sales contract and a financing statement under the registered trade name as follows:

“Landman Dry Cleaners By: Matthew R. Leichter”

As in the case sub judice, the financing statement was indexed only under the bankrupt’s assumed business name. The inquiry undertaken by the Second Circuit focused on whether a subsequent creditor of “Leichter” would be led to find the security interest filed and indexed under “Landman”. 4 The court held that persons searching the records would not be put on notice by such a filing and thereby held it to be insufficient. A similar result was reached in In re Thomas, 466 F.2d 51 (9th Cir. 1972), where the correct name of the *372 debtor was Burris Haley Thomas, but the debtor’s name was listed in the financing statement only as West Coast Avionics. The court held that “[i]t can hardly be said to be a ‘minor error’ when a potential creditor of Burris Haley Thomas searches the index under ‘Thomas’ and finds no notice of a security interest because that notice is filed under ‘West Coast Avionics’.” 5 Although the provisions of the Georgia version of the Uniform Commercial Code are to be liberally construed, the underlying purpose of the code’s notice filing system would be frustrated by a holding that a financing statement filed and indexed only under the name “National Photocopy Equipment Co.” gave notice to creditors of Firth. One searching the records under the name of the debtor, Firth, would simply not discover the security interest of the bank.

The case of National Cash Register Co. v. Sikes, supra, is of little aid to the bank, not only because it was decided prior to the effective date of the Georgia Uniform Commercial Code but also because the facts there are distinguishable from the instant case. The court there held that a title retention contract signed “Dixie Service Station by Allen Roth” did not import the name of any legal or artificial person, so it was obvious that the obligation was assumed by the person signing the instrument, i. e. by Roth. When a financing statement is signed “National Photocopy Equipment Co. by James A. Firth”, however, the clear implication is that the individual party signs on behalf of the real debtor, National Photocopy Equipment Co. The signature does import the name of a legal or artificial person. Moreover, insofar as the formal requirements of Ga.Code Ann. § 109A-9— 402(1) are concerned, the real debtor, Firth, has not signed in his individual capacity but only on behalf of a fictitious business entity; the financial statement is therefore conceptually insufficient since the signature of the real debtor in his real name does not appear thereon.

The Georgia statute relating to the capacity of persons to contract under unregistered trade names is likewise unpersuasive, i. e. 1933 Ga.Code Ann.

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Bluebook (online)
363 F. Supp. 369, 180 U.S.P.Q. (BNA) 306, 13 U.C.C. Rep. Serv. (West) 343, 1973 U.S. Dist. LEXIS 12015, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-firth-gamd-1973.