PNC Equipment Finance, LLC v. Joseph P. Lopez

CourtUnited States Bankruptcy Court, W.D. Michigan
DecidedJuly 20, 2021
Docket19-80049
StatusUnknown

This text of PNC Equipment Finance, LLC v. Joseph P. Lopez (PNC Equipment Finance, LLC v. Joseph P. Lopez) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PNC Equipment Finance, LLC v. Joseph P. Lopez, (Mich. 2021).

Opinion

UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF MICHIGAN

In re: Case No. DG 18-03292 JOSEPH P. LOPEZ, Hon. Scott W. Dales Chapter 7 Debtor. _____________________________________/

PNC EQUIPMENT FINANCE, LLC,

Plaintiff, Adversary Pro. No. 19-80049

v.

JOSEPH P. LOPEZ,

Defendant.

_____________________________________/

MEMORANDUM OF DECISION AND ORDER

PRESENT: HONORABLE SCOTT W. DALES Chief United States Bankruptcy Judge

On June 9, 2021, the court granted the motion of Defendant Joseph P. Lopez (the "Defendant" or "Mr. Lopez") for summary judgment, declaring his debt to Plaintiff PNC Equipment Finance, LLC ("PNCEF" or "Plaintiff") discharged notwithstanding the purported exception under 11 U.S.C. § 523(a)(2)(A). On June 23, 2021, PNCEF timely filed a notice of appeal and a motion to reconsider the summary judgment (the "Reconsideration Motion," ECF No. 78). The Defendant filed a response on July 8, 2021 (ECF No. 82, the "Response"), and PNCEF filed its reply on July 15, 2021 (ECF No. 83, the "Reply").1

1 A similar recitation describes the filings in a companion case involving Mr. Lopez's former business partner, PNC Equipment Finance, LLC. v. Darin, Adv. No. 19-80051. The court has reviewed the Reconsideration Motion, the Response, and the Reply, and will deny the Reconsideration Motion based upon the well-established standards governing such motions. See In re Solomon, 436 B.R. 451, 453 (Bankr. W.D. Mich. 2010); In re Ying Ly, 350 B.R. 757 (Bankr. W.D. Mich. 2006) (A party seeking reconsideration must establish a clear error of law, newly discovered evidence, an intervening change in controlling law, or the need to prevent

manifest injustice). In its Reconsideration Motion, PNCEF simply reiterates oral and written arguments the court previously rejected in the Memorandum of Decision and Order dated June 9, 2021 (ECF No. 75, the "MDO") (reported as PNC Equipment Finance LLC v. Darin (In re Darin), Slip Op. Adv. No. 19-80051, 2021 WL 2389770 (Bankr. W.D. Mich. June 9, 2021)). For example, the court previously considered the possibility that PNCEF lacked control over the deposit accounts of JDJ Hospitality, LLC ("JDJ"), concluding that even in the absence of a control agreement PNCEF may be automatically perfected in proceeds of its other collateral. The court found -- based on authority that PNCEF itself submitted -- that PNCEF must offer "proof that assets were available for transfer

that were not encumbered by a valid lien." See MDO at p. 15 (citing Steinberg v. Young, Slip Op. No. 09-11836, 2010 WL 3190849, at *6 (E.D. Mich. Aug. 11, 2010)). PNCEF's recent though untimely submission of a deposit account agreement (offered to refute the court's suggestion that a commercial deposit account agreement might qualify as a "control agreement" under M.C.L. § 440.9104(1)(a)) misses the point. Indeed, the court's decision to enter summary judgment did not depend on the inference that PNCEF had control of the deposit account, but instead on the fact that PNCEF had not established as a matter of fact that its security interest in deposit accounts was not perfected by control or by automatic perfection in the accounts as proceeds of other collateral in which PNCEF repeatedly claimed it held perfected security interests.2 Even if the deposit account agreement could qualify as newly discovered evidence,3 it would not have changed the result then, and it does not move the court now. The court found that PNCEF, as the party with the burden of proof, did not meet its summary judgment burden under Rule 56. PNCEF next argues as a matter of law that JDJ's deposit accounts qualified as "assets" that

could be the subject of a "transfer" under Michigan's Uniform Voidable Transfer Act ("MUVTA") even if PNCEF had a perfected security interest in the deposit accounts, because its security interest would not qualify as a "valid lien" in the deposit accounts. This is so, according to PNCEF, because a "lien creditor" is a "transferee of funds" who takes free of security interests in a deposit account. PNCEF cites M.C.L. § 440.9332(2)4 and an unreported decision of an out-of-jurisdiction court applying California law in support. See Stierwalt v. Associated Third Party Administrators, Slip Op. Case No. 16-mc-80059-EMC, 2016 WL 2996936 (N.D. Calif. May 25, 2016). Stierwalt held that a lien creditor qualifies as a transferee of funds from a deposit account and, in the absence of collusion,5 takes free of a perfected security interest in the deposit account.

Michigan law, however, provides that a lien creditor who garnishes a deposit account does not immediately obtain any "funds" at the moment it serves the garnishment writ, only an execution lien in the deposit account, pending the outcome of the post-judgment proceedings. Michigan

2 See MDO at pp. 13-14 ("The court is not inferring that PNC Bank's depository agreement included such a provision (though it might have) but only that the Plaintiff who has throughout this proceeding . . . asserted a perfected security interest in the property transferred ought to have marshalled some evidence to contradict its earlier positions . . .") and p. 16 ("Even if the evidence at trial might establish that PNCEF did not benefit from a control agreement, PNCEF likely enjoyed automatic perfection of its security interest in the restaurant's deposit accounts under M.C.L. § 440.9315(3) and (4), and after discovery it should have been able to make a prima facie showing, in the words of the Steinberg court, 'that assets were available for transfer that were not encumbered by a valid lien.'"). 3 PNCEF obviously knew that a deposit account agreement existed, but did not bother to locate it after the court signaled the importance of the issue in its Rule 56(f) notice, at least not until after the court entered judgment. 4 Under this section, "[a] transferee of funds from a deposit account takes the funds free of a security interest in the deposit account unless the transferee acts in collusion with the debtor in violating the rights of the secured party." M.C.L. § 440.9332(2). 5 PNCEF would have a Herculean task establishing the absence of collusion given its theory of the case. Tractor & Mach. Co. v. Elsey, 549 N.W.2d 27, 29 (Mich. App. 1996) ("Michigan follows the general rule that a garnishment lien attaches upon service of the writ."); M.C.R. 3.101 (Garnishment After Judgment). Stated differently, a lien creditor is not a "transferee of funds" under M.C.L. § 440.9332(2) when its garnishment lien attaches, just as an ordinary secured creditor is not a "transferee of funds" when its security interest attaches: both hold an interest in

the account, not the funds themselves. Indeed, a deposit account in Michigan simply represents the depository institution's debt to its depositor. Riverview Co-op., Inc. v. First Nat. Bank & Trust Co., 337 N.W.2d 225, 229 (Mich. 1983) (the "relationship between a depositor and a bank … is one of debtor and creditor"). A garnishing creditor simply encumbers the depository's obligation to the depositor upon service of the writ. At that point in time, when the garnishment lien attaches, the depository institution must withhold the funds, not transfer them. See M.C.R. 3.101(I) (Withholding). And, the general theory of garnishment in Michigan is that a judgment creditor steps into the shoes of the judgment debtor,6 not the shoes of the judgment debtor's transferee.

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Related

Riverview Cooperative, Inc. v. First National Bank & Trust Co.
337 N.W.2d 225 (Michigan Supreme Court, 1983)
Crehan v. Ying Ly (In Re Ying Ly)
350 B.R. 757 (W.D. Michigan, 2006)
Michigan Tractor & MacHinery Co. v. Elsey
549 N.W.2d 27 (Michigan Court of Appeals, 1996)
In Re Solomon
436 B.R. 451 (W.D. Michigan, 2010)
Husky International Electronics, Inc. v. Ritz
578 U.S. 355 (Supreme Court, 2016)

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PNC Equipment Finance, LLC v. Joseph P. Lopez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pnc-equipment-finance-llc-v-joseph-p-lopez-miwb-2021.