Unisource Canada Inc. v. Hongkong Bank of Canada, et al.

Unisource Canada Inc. v. Hongkong Bank of Canada, et al.

The court held that a portion of each accounts receivable equal to the unpaid price of the paper supplied by the appellant constituted proceeds of the appellant's PMSI and ranked first, but once those receivables were paid and the sums deposited into Johanns Graphics Inc.'s general bank account the proceeds could...

Source-derived case information.

Citation
C31233
Parties
Appellant: Unisource Canada Inc., successor to Abitibi-Price Inc., carrying on business under the firm name and style of Barber-Ellis Fine Papers/Papeterie Barber-Ellis; Respondent: Hongkong Bank of Canada; Respondent: Peat Marwick Thorne Inc.; Respondent: Andrew Csanady; Respondent: Janne Csanady also known as Janne D. E. Janke; Respondent: Bruce Braid; Respondent: Thomas Bull; Respondent: Lance Crawford; Respondent: Timothy Decker; Respondent: Robert Dockeray; Respondent: Barbara Braid; Respondent: Barbara Bull; Respondent: Wendy Crawford; Respondent: Robin Decker; Respondent: Anne Dockeray
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
24 March 2000
Procedural Posture
Civil / Appeal From Trial Decision
Outcome
Appeal allowed in part and dismissed in part
Legal Topics
PMSI, Priority of Security Interests, Proceeds Tracing, Corporate Reorganization, Interest, Costs
Source Language
en
Commercial Law Secured Transactions Banking Law Civil Procedure PMSI Priority of Security Interests Proceeds Tracing Corporate Reorganization +2 more

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Parties

Unisource Canada Inc., successor to Abitibi-Price Inc., carrying on business under the firm name and style of Barber-Ellis Fine Papers/Papeterie Barber-Ellis

Appellant

Hongkong Bank of Canada

Respondent

Peat Marwick Thorne Inc.

Respondent

Andrew Csanady

Respondent

Janne Csanady also known as Janne D. E. Janke

Respondent

Bruce Braid

Respondent

Thomas Bull

Respondent

Lance Crawford

Respondent

Timothy Decker

Respondent

Robert Dockeray

Respondent

Barbara Braid

Respondent

Barbara Bull

Respondent

Wendy Crawford

Respondent

Robin Decker

Respondent

Anne Dockeray

Respondent

Procedural Posture

Civil / Appeal From Trial Decision

  1. 1 Whether the corporate reorganization of Johanns Graphics Inc. provided a valid basis for a security interest
  2. 2 Whether the appellant's purchase-money security interest (PMSI) gave priority in accounts receivable and their proceeds
  3. 3 Whether proceeds paid into the debtor's general bank account could be traced to preserve PMSI priority

Ratio Decidendi

The court held that a portion of each accounts receivable equal to the unpaid price of the paper supplied by the appellant constituted proceeds of the appellant's PMSI and ranked first, but once those receivables were paid and the sums deposited into Johanns Graphics Inc.'s general bank account the proceeds could not be traced and the PMSI priority disappeared; except for the preserved PMSI portion, priority was Bank first, Owners Group second, appellant third, and the appellant was entitled to accrued interest on the approximately $66,000 recovered.

Court Disposition

Appeal allowed in part and dismissed in part

Orders

  • Appeal allowed to the extent of awarding pre-judgment and post-judgment interest on the amount recovered as to the appellant (approximately $66,000)
  • Appeal dismissed in all other respects