Bank of Boston vs Jones UCC-1 Perfection Issue - Need Help Understanding Security Interest Priority
I'm working on a complex secured transaction case and keep running into questions about the Bank of Boston vs Jones decision (4 UCC Rep. Serv. 1021, 236 A.2d 484). My client filed a UCC-1 financing statement but there's a priority dispute with another creditor who claims their interest was perfected first. The case seems to involve UCC 9-109.14 provisions but I'm struggling to understand how the court's reasoning applies to our situation. Our debtor is a equipment leasing company and we have collateral that includes both fixtures and moveable equipment. The other creditor filed their UCC-1 about 6 months after us but they're claiming some kind of purchase money security interest priority. Has anyone dealt with similar Bank of Boston vs Jones type priority conflicts? I need to understand if our earlier filing date gives us the protection we think it does or if there are exceptions I'm missing. The dollar amounts involved are substantial and I don't want to advise my client incorrectly about their security position.
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Emma Thompson
The Bank of Boston case is tricky because it involves both timing and classification issues. When you say the other creditor is claiming PMSI priority, are they claiming it on the fixtures or the moveable equipment? That makes a huge difference under 9-109.14. For fixtures, they'd need to file before or within 20 days of the debtor receiving possession. For equipment, it's different timing rules.
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Javier Mendoza
•They're claiming PMSI on some specialized manufacturing equipment that was installed after our original UCC-1 filing. The equipment could arguably be considered fixtures since it's bolted down and integrated into the production line. That 20-day rule you mentioned - is that from when the equipment was delivered or when it was actually installed and operational?
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Emma Thompson
•For fixtures, it's typically when the goods become fixtures, not just delivery. But the Bank of Boston decision shows courts can be very fact-specific about what constitutes 'becoming a fixture.' You need to look at the integration with the real property and whether removal would cause material harm to the building or equipment.
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Malik Davis
I had a similar situation last year and got completely confused about the priority rules until I found Certana.ai's UCC document verification tool. You can upload your UCC-1 and their competing filing to instantly cross-check the dates, debtor names, and collateral descriptions. It helped me spot a debtor name discrepancy in the competing filing that actually invalidated their claim. The tool shows you exactly what to look for in these priority disputes.
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Isabella Santos
•Wait, are you saying their UCC-1 might have defects that could void their PMSI claim? I've been so focused on the timing aspects I didn't think about technical filing errors.
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Malik Davis
•Exactly! PMSI priority doesn't help if the filing itself is defective. Certana.ai caught things like slight debtor name variations and incomplete collateral descriptions that can completely undermine a security interest. It's worth checking before you concede any priority claims.
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Javier Mendoza
•That's a good point. I should verify their filing is actually valid before worrying about their priority claim. Do you know if the tool handles fixture filing requirements too?
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StarStrider
Bank of Boston vs Jones is one of those cases that gets cited constantly but the facts are so specific. Are you dealing with a purchase money security interest in fixtures or just equipment? Because the analysis changes completely. Also, did the competing creditor file a fixture filing or just a regular UCC-1? That matters for priority.
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Javier Mendoza
•They filed a regular UCC-1, not a fixture filing. But they're claiming the equipment is fixtures and that their PMSI gives them priority. I'm not sure if they can claim fixture status without doing a proper fixture filing in the real estate records.
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StarStrider
•That's your answer right there! If they're claiming fixture priority but didn't file a proper fixture filing, they're probably out of luck. Regular UCC-1 filings don't give you the same priority for fixtures as a proper fixture filing would.
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Ravi Gupta
ugh why do these priority rules have to be so complicated?? I spent 3 hours yesterday trying to figure out whether some restaurant equipment counted as fixtures or not. The Bank of Boston case doesn't make it any clearer either - seems like every situation is different.
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Freya Pedersen
•Tell me about it. I had a case where the debtor's name was slightly different between the charter documents and the UCC filing and it took months to sort out the priority mess.
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Omar Hassan
•That's why I always double-check everything now. One little mistake in debtor name or collateral description can blow up your entire security interest.
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Chloe Anderson
The key issue in Bank of Boston vs Jones was whether the creditor properly perfected their security interest according to the applicable UCC provisions. In your case, you need to determine: 1) Is the collateral actually fixtures requiring a fixture filing? 2) Did they comply with PMSI timing requirements? 3) Is their UCC-1 filing technically sufficient? Priority often comes down to these technical details rather than just filing dates.
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Javier Mendoza
•Those are exactly the questions I need to analyze. The equipment is bolted down but it's specialized manufacturing equipment that could potentially be removed and relocated. Not sure if that makes it fixtures or moveable equipment under the UCC.
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Diego Vargas
•Look at whether removal would damage the building or the equipment itself. Also check if it's integrated into the building's systems (electrical, plumbing, etc.). That usually determines fixture status.
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CosmicCruiser
I remember the Bank of Boston case from law school but honestly the practical application is always messier than the textbook version. Have you looked at whether their PMSI notice requirements were met? Sometimes creditors forget about the notification obligations to existing secured parties.
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Javier Mendoza
•Good point - I don't recall receiving any PMSI notification from them. If they were required to give notice and didn't, does that affect their priority claim?
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CosmicCruiser
•For inventory PMSI, notice is required. For equipment PMSI, it usually isn't. But if they're claiming fixture status, different rules might apply. You should check the specific notice requirements for your situation.
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Anastasia Fedorov
Just went through something similar with a client. Turned out the competing creditor's UCC-1 had the wrong business name - they used the trade name instead of the legal entity name. Completely invalidated their filing even though they claimed PMSI priority. Certana.ai's verification tool would have caught that immediately by comparing against the charter documents.
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Javier Mendoza
•That's exactly the kind of detail that could resolve this whole dispute. I should definitely verify their debtor name matches the legal entity exactly.
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Sean Doyle
•Yeah, debtor name accuracy is critical. Even small differences can void the entire filing. I've seen cases lost over missing 'Inc.' or 'LLC' designations.
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Zara Rashid
The Bank of Boston decision really emphasizes the factual nature of these determinations. Every case depends on the specific equipment, installation method, and integration with the property. You might need expert testimony about whether the equipment constitutes fixtures under applicable state law.
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Javier Mendoza
•That's a good suggestion. An expert could help establish whether the equipment is truly integrated as fixtures or remains moveable equipment subject to different priority rules.
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Luca Romano
•Make sure the expert understands both the legal test for fixtures and the practical aspects of the equipment installation. The court will want to understand the real-world implications of removal.
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Nia Jackson
Priority disputes are always stressful because so much money is at stake. But Bank of Boston vs Jones shows that courts really focus on whether each creditor followed the proper perfection procedures. If their PMSI claim is based on fixture status but they didn't file properly for fixtures, that's probably your winning argument.
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Javier Mendoza
•Right, if they're claiming fixture priority without doing a fixture filing, that seems like a fundamental error in their perfection strategy.
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NebulaNova
•Exactly. You can't have it both ways - either it's fixtures requiring proper fixture filing procedures, or it's equipment subject to regular UCC-1 timing rules.
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Mateo Hernandez
Have you considered that there might be multiple pieces of collateral with different classifications? Some equipment might qualify as fixtures while other pieces remain moveable. The Bank of Boston analysis might apply differently to each category of collateral.
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Javier Mendoza
•That's a complicating factor I hadn't fully considered. The collateral does include both permanently installed processing equipment and mobile transport equipment. I may need to analyze priority separately for each category.
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Aisha Khan
•Definitely analyze each piece separately. Priority rules can vary significantly between different types of collateral even within the same transaction.
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Ethan Taylor
•This is getting complex fast. Make sure you document the analysis for each category clearly - courts hate when lawyers treat dissimilar collateral as one big group.
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Monique Byrd
The Bank of Boston case really highlights how critical it is to get the technical details right in these priority disputes. From what you've described, it sounds like the competing creditor may have several potential weaknesses: (1) claiming fixture status without proper fixture filing procedures, (2) possible defects in their UCC-1 filing itself, and (3) potential timing issues with their PMSI claim. I'd suggest starting with a thorough review of their actual filing - check the debtor name against charter documents, verify the collateral description is sufficient, and confirm they met all technical requirements. If they're claiming PMSI priority on fixtures, they absolutely need to have filed properly in the real estate records within the required timeframe. The fact that they only filed a regular UCC-1 but are claiming fixture priority seems like a fundamental contradiction that could invalidate their entire position.
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Charlotte Jones
•This is really helpful analysis! As someone new to UCC priority disputes, I'm learning a lot from this discussion. It sounds like there are multiple angles to attack their claim - the fixture filing issue seems particularly strong if they're trying to claim fixture priority without following proper fixture filing procedures. One question: if you find defects in their UCC-1 filing, does that completely void their security interest or just affect their priority position relative to other creditors?
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