National Car Rental v. Fox

500 P.2d 1148, 18 Ariz. App. 160, 11 U.C.C. Rep. Serv. (West) 320, 1972 Ariz. App. LEXIS 809
CourtCourt of Appeals of Arizona
DecidedSeptember 14, 1972
Docket1 CA-CIV 1814
StatusPublished
Cited by7 cases

This text of 500 P.2d 1148 (National Car Rental v. Fox) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Car Rental v. Fox, 500 P.2d 1148, 18 Ariz. App. 160, 11 U.C.C. Rep. Serv. (West) 320, 1972 Ariz. App. LEXIS 809 (Ark. Ct. App. 1972).

Opinion

KRUCKER, Chief Judge.

This appeal is concerned with priority rights in a 1967 Cadillac and a 1968 Buick as between the plaintiff-appellee, Norman Fox (hereinafter referred to as plaintiff) and defendant-appellant, National Car Rental Corporation (hereinafter referred to as defendant).

Facts relevant to this determination arise out of the circumstances of the transfer of these two automobiles in December, 1968, by plaintiff to River Ranch Sales Corporation (hereinafter referred to as River Ranch) and a subsequent transfer of these automobiles by River Ranch to the defendant.

Prior to these transfers, both plaintiff and defendant, automobile dealers, had been using the services of River Ranch for the purpose of selling used or rental vehicles at auction. Plaintiff, an out-of-state dealer, typically carried out these transactions by signing over to River Ranch the out-of-state titles to these vehicles. By virtue of these transfers, River Ranch would receive an Arizona Certificate of Title. River Ranch would then furnish invoices to plaintiff which designated him as “consignor.”

While these invoices itemized “expenses advanced,” we are unable to determine from the record the method of ascertaining the cost of River Ranch’s services (i. e., whether a fixed price or a percentage of the profits). In any event, after the sale, River Ranch would issue a check to the dealer furnishing the car.

In December, 1968, plaintiff transferred the two cars in question in the above-described manner. According to the deposition of Warren Holt, manager of defendant’s sales and operations, shortly after these transfers occurred, the defendant was holding uncollectable checks issued to defendant by River Ranch totalling $30,000. In an effort to salvage some of this loss, Holt went to River Ranch and exchanged two checks totalling $7,460 for the two automobiles in question.

A replevin action was commenced by plaintiff seeking return of these two vehicles or their reasonable value. Since a writ of replevin had issued restoring possession to the plaintiff, the defendant requested the reasonable value of the vehicles and damages for loss of use. At the *162 time the suit was commenced, their reasonable value was $7,460 and their fair rental value was $10 per day.

Both parties moved for summary judgment. Plaintiff contended that A.R.S. § 44 — 2343, subsec. C, par. 2 1 (U.C.C. 2-326(3) (b)) controlled, arguing that defendant was a creditor of River Ranch and that River Ranch was generally known by its creditors as engaged in selling goods of another.

Defendant, in opposition to this motion, argued to the contrary, maintaining that this subsection, which plaintiff relied on, only covers consignment arrangements and the transaction between plaintiff and River Ranch was a “sale.” In support of its own motion, it contended it was a “good faith purchaser for value” under A.R.S. § 44— 2348, subsec. A 2 (U.C.C. 2-403(1)) when it received two automobiles in satisfaction of River Ranch’s pre-existing debt.

From a summary judgment in favor of the plaintiff finding A.R.S. § 44-2343 applicable and controlling, and a finding that plaintiff had established that River Ranch was engaged in a business generally known by its creditors as selling goods of others, defendant appeals.

The questions presented to this court on review are:

1. Was the defendant a creditor of or a purchaser from River Ranch when it acquired the two vehicles?
2. Is the transaction between River Ranch and plaintiff governed by A.R.S. § 44-2343?
3. Was the plaintiff entitled to relief as a matter of law ?

IS THE DEFENDANT A CREDITOR OF, OR A PURCHASER FROM RIVER RANCH?

Defendant correctly points out that A.R.S. § 44-2348, subsec. A protects a “purchaser for value” who obtains goods from those who have voidable title. A.R.S. § 44 — 2343, on the other hand, protects creditors of those in possession of the goods. American National Bank v. Tina Marie Homes, Inc., 28 Colo.App. 477, 476 P.2d 573 (1970); American National Bank v. Christensen, 28 Colo.App. 501, 476 P.2d 281 (1970); American National Bank v. First National Bank, 28 Colo.App. 486, 476 P.2d 304 (1970); Sussen Rubber Co. v. Hertz, 19 Ohio App.2d 1, 249 N.E.2d 65 *163 (1969) ; Guardian Discount Co. v. Settles, 114 Ga.App. 418, 151 S.E.2d 530 (1966). (For a discussion of types of people covered under the two statutes, see, 14 Catholic U.L.Rev. 89 (1965).) While admitting it is not a “buyer in the ordinary course of business” under A.R.S. § 44-2348, subsecs. B or C, the defendant contends it is a “purchaser for value” and therefore A.R.S. § 44 — 2348, subsee. A rather than § 44 — 2343, subsee. C is controlling as to this cause.

*162 “A. A purchaser of goods acquires all title which his transferor had or had power to transfer except that a purchaser of a limited interest acquires rights only to the extent of the interest purchased. A person with voidable title has power to transfer a good title to a good faith purchaser for value. When goods have been delivered under a transaction of purchase the purchaser has such power . . . .”

*163 In considering the merit of this argument, it is necessary to determine under what circumstances one takes by “purchase.” 3 At common law, courts in a majority of jurisdictions had taken the position that a pre-existing debt was not sufficient consideration for the purchase of a chattel and therefore such a person was not a “bona fide purchaser for value.” His status as creditor, therefore, remained unchanged. See, citations in 11 A.L.R.3d 1028 § 3; Am.Jur. Sales §§ 467 and 472.

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Bluebook (online)
500 P.2d 1148, 18 Ariz. App. 160, 11 U.C.C. Rep. Serv. (West) 320, 1972 Ariz. App. LEXIS 809, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-car-rental-v-fox-arizctapp-1972.