Washington Law Review


Norman B. Page


The Washington Supreme Court held, in Architectural Woods, Inc. v. State, that the assignment fell within section 9-302(1)(e) and that since plaintiffs security interest was thus automatically perfected, the bank's interest was subordinate." In deciding that Didco's assignment to plaintiff fell within the section 9-302(1)(e) exemption from filing, the court was required to construe the language of that subsection and its accompanying official comment. More particularly, the court considered the appropriate test for determining whether the assignment constituted a "significant part" of Didco's outstanding accounts and contract rights. This note will analyze the court's reasoning in adopting the "casual and isolated" test, compare opinions from other courts construing the same subsection, and argue that the court's reasons fail to support the result reached. Finally, it will propose a means of construing the exemption which is more consonant with both the literal statutory language and Article 9's dominant policy of protecting innocent creditors against secret transfers of collateral.

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