RCA Corp. v. Video East, Inc. (In Re Video East, Inc.)

41 B.R. 176, 39 U.C.C. Rep. Serv. (West) 695, 1984 Bankr. LEXIS 5502
CourtUnited States Bankruptcy Court, E.D. Pennsylvania
DecidedJune 13, 1984
Docket19-10675
StatusPublished
Cited by3 cases

This text of 41 B.R. 176 (RCA Corp. v. Video East, Inc. (In Re Video East, Inc.)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RCA Corp. v. Video East, Inc. (In Re Video East, Inc.), 41 B.R. 176, 39 U.C.C. Rep. Serv. (West) 695, 1984 Bankr. LEXIS 5502 (Pa. 1984).

Opinion

OPINION

EMIL F. GOLDHABER, Bankruptcy Judge:

Three predominant issues are presented in the case at bench, the first of which is whether a creditor’s security interests in equipment are unperfected pursuant to 13 Pa.Cons.Stat. § 9103(a)(4) of the Uniform Commercial Code (“UCC”) of Pennsylvania. The second issue is whether we should avoid a creditor’s security interest under 11 U.S.C. § 506 of the Bankruptcy Code (“the Code”) on the averment that the amount of the secured claim exceeds the value of the collateral. And finally, we must determine if we should grant a creditor’s request for relief from the automatic stay in order to permit foreclosure on the debtor’s collateral. On the first issue we find the security interests are unperfected and on the second issue we will avoid that security interest in part. We will grant the request for relief from the stay on the third issue.

The facts of this case are as follows: 1 An involuntary petition for relief under chapter 7 of the Code was filed against the debtor on December 31, 1981. The debtor failed to controvert the petition, relief was entered, and thereafter the case was converted to a chapter 11 proceeding at the debtor’s request. RCA Corporation (“RCA”) commenced the action at bench seeking relief from the automatic stay on the basis that the debtor was in default on a purchase money financing agreement under which the debtor had purchased the equipment. On receipt of said equipment, the debtor promptly installed it in the company van. The debtor contended that RCA was not entitled to relief from the stay on the alternative theories that RCA's security interests in numerous pieces of equipment in the van were not perfected and that RCA’s interest in the remainder of the collateral, which was subject to a perfected security interest, was adequately protected. The debtor counterclaimed, seeking the avoidance of the unperfected security interests under 11 U.S.C. § 544(a) and the avoidance of the perfected security interest under 11 U.S.C. § 506 to the extent that the indebtedness exceeded the fair market value of the goods.

Prior to the filing of the petition in bankruptcy, the debtor was in the business of filming and videotaping various sports events on the East Coast. The debtor purchased video equipment from RCA on credit under four security agreements. After its installation in the van, the equipment was transported in the vehicle to various filming sites. When the debtor’s business began in 1979, the van was garaged in a leased facility in Camden, New Jersey. At that time the debtor’s headquarters were located on Vassar Road, Strafford, Chester County, Pennsylvania, in a spare room in the home of one of the debtor’s principals, one Henry H. Briggs, III (“Briggs”). Due to the expansion of the business, the debtor moved its offices in February of 1980 to North Gulph Road, King of Prussia, Montgomery County, Pennsylvania, and ceased conducting business in Chester County. In July of 1981 further expansion caused the debtor to move from North Gulph Road to *178 Fifth Avenue, King of Prussia, Montgomery County, Pennsylvania. With that move the van was no longer housed in Camden, but it was “brought into and kept” at the Fifth Avenue address in Pennsylvania and garaged there.

The parties are in agreement that all merchandise sold under the security agreements was “equipment” within the meaning of the UCC of Pennsylvania and New Jersey and that the security interest on the goods purchased under the fourth security agreement was perfected. On their last major point of agreement the parties concur that the goods delivered under the first three security agreements were perfected when those goods were delivered to the debtor’s garage in New Jersey.

Goods purchased under the first three agreements were received prior to May of 1981 and these goods were delivered to Camden and placed in the van. Financing statements for each of these purchases were filed in the appropriate state-wide filing locations for New Jersey and Pennsylvania (Trenton and Harrisburg) and in the duly authorized local offices in Camden County, New Jersey and Chester County, Pennsylvania. Goods purchased under the fourth security agreement which, according to the evidence, have a value of $24,-000.00, were received in May of 1981 at North Gulph Road in Montgomery County, Pennsylvania. Financing statements were filed in Pennsylvania’s state-wide filing office in Harrisburg as well as in the Pennsylvania counties of Delaware, Montgomery and Chester.

Although the merchandise was initially perfected under New Jersey’s UCC, the debtor contends that RCA’s failure to file the requisite financing statements in Pennsylvania after the debtor purportedly began housing the van in Pennsylvania, caused the security interests to lapse in accordance with Pennsylvania’s UCC. Since this is a multiple state transaction under Article 9 of the UCC, we have quoted below the relevant provision of Pennsylvania’s UCC: § 9103. 2 13 Pa.Con.Stat. § 9103. Since the merchandise delivered to the van was goods other than minerals, mobile goods or goods covered by a certificate of title, § 9103 applies to the facts of the case at bench. § 9103(a)(1). Except as otherwise provided in § 9103, § 9103(a)(2) indicates that New Jersey’s UCC would govern this case since the last event giving rise to the alleged security interest in the *179 equipment occurred in that state. Nonetheless, § 9103(a)(4), in conjunction with § 9302 of chapter 93, provides that a secured party must file the appropriate financing statements in Pennsylvania if the security interest is to continue perfected more than four months after the equipment is “brought into and kept in” Pennsylvania.

The first issue we must address is whether the equipment was “brought into and kept” in Pennsylvania so as to necessitate the filing of financing statements in accordance with Pennsylvania’s UCC. We stated above that equipment was, in fact, “brought into and kept” in this state when the van was first housed in the garage in King of Prussia, Pa., rather than in Camden. At that time the van and the equipment contained in it, were clearly “brought” into Pennsylvania and we conclude that occasional conveyance of the equipment in the van to neighboring states for filming did not preclude the determination that the equipment was “kept” in Pennsylvania. See, e.g., In Re Bob Schwermer & Assoc., Inc., 27 B.R. 304 (Bankr.N.D.Ill.1983) (race horses which were deemed equipment under the UCC were “kept” in the state where horses were customarily maintained within the meaning of § 9-103 and thus remained the subject of a continuously perfected security interest notwithstanding the transportation of the horses to race tracks in other states); Rothman v. Deckelbaum (In Re Potomac School of Law, Inc.), 16 B.R.

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Bluebook (online)
41 B.R. 176, 39 U.C.C. Rep. Serv. (West) 695, 1984 Bankr. LEXIS 5502, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rca-corp-v-video-east-inc-in-re-video-east-inc-paeb-1984.