In American Surety Co. v. Sundberg the Washington Supreme Court made a startling encroachment upon the sanctity of a secured mortgage. Using the United States Supreme Court's test of "choateness," the court held that the lien of a mortgage securing future advances is subordinate to federal tax liens filed subsequent to the filing of the mortgage, but prior to advances for which the lien was claimed.
Beverly J. Rosenow,
Washington Case Law,
Security Transactions—Priority—Federal Tax Liens and Future Advance Mortgages,
37 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol37/iss2/15