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Lavonia Manufacturing Co. v. Emery Corp. (In Re Emery Corp.)
United States Bankruptcy Court, E.D. Pennsylvania (1984) | 1984 Bankr. LEXIS 6064; 38 B.R. 489; 38 U.C.C. Rep. Serv. (West) 834
TL;DR: A seller sought to reclaim goods from an insolvent buyer. The court held the seller's reclamation right under UCC § 2-702 prevails over a creditor's pre-existing, perfected security interest in the buyer's after-acquired property, as the secured creditor is not a "good faith purchaser" for this purpose.
Legal Significance: This case establishes that a seller's UCC § 2-702 reclamation right is superior to a pre-existing security interest in after-acquired property. It rejects the influential In re Samuels view, holding that reclamation is a right of rescission, not a subordinate security interest.