dragnet clause (Mississippi) · Go Syfert
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dragnet clause in Mississippi

11 Mississippi opinions name it 1 courts 1953–1998 0 in the last five years

The cases below were cited by Mississippi courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Walters v. M. & M. BANK OF ELLISVILLEgreen
miss · 1953 · cited in 3 Mississippi opinions naming this issue, 1971–1995
2 sentences

1971We stated: Where the clause is broad enough to cover subsequent debts of one of joint mortgagors, the dragnet clause is generally construed so as to extend the security of the mortgage executed by joint mortgagors to the individual indebtedness of one of them afterward created. *373 * * * ( 218 Miss. at 784 , 67 So.2d at 717 ). * * * * * * The parties clearly agreed that it would secure debts incurred by both of them and by either of them.

1971We stated: Where the clause is broad enough to cover subsequent debts of one of joint mortgagors, the dragnet clause is generally construed so as to extend the security of the mortgage executed by joint mortgagors to the individual indebtedness of one of them afterward created. *373 * * * ( 218 Miss. at 784 , 67 So.2d at 717 ). * * * * * * The parties clearly agreed that it would secure debts incurred by both of them and by either of them.

23
Wong v. Beneficial Savings & Loan Ass'ngreen
calctapp · 1976 · cited in 2 Mississippi opinions naming this issue, 1996–1998
2 sentences

1998Stewart, 608 So.2d at 1126 (citing Mark Twain Kansas City Bank v. Cates, 248 Kan. 700 , 810 P.2d 1154 (1991); Shiew, 609 P.2d at 957-58 ; Wong v. Beneficial Sav. and Loan Ass'n, 56 Cal.App.3d 286 , 128 Cal. Rptr. 338, 342 (1976)).

1998Stewart, 608 So.2d at 1126 (citing Mark Twain Kansas City Bank v. Cates, 248 Kan. 700 , 810 P.2d 1154 (1991); Shiew, 609 P.2d at 957-58 ; Wong v. Beneficial Sav. and Loan Ass'n, 56 Cal.App.3d 286 , 128 Cal. Rptr. 338, 342 (1976)).

22
Holland v. Bank of Lucedalegreen
miss · 1967 · cited in 2 Mississippi opinions naming this issue, 1992–1995
2 sentences

1995Newton County Bank v. Jones, 299 So.2d 215, 219-20 (Miss. 1974); Holland v. Bank of Lucedale, 204 So.2d 875, 877 (Miss. 1967).

1992See Davis, 168 So. at 262 (in deed of trust executed by husband and wife, dragnet clause which secured future advances made to "them" did not secure advance made only to husband); Holland v. Bank of Lucedale, 204 So.2d 875, 877 (Miss. 1967) (same); Walters v. Merchants & Manufacturers Bank of Ellisville, 218 Miss. 777 , 67 So.2d 714, 717 (1953) (same).

22
Matter of Ladnergreen
mssb · 1985 · cited in 3 Mississippi opinions naming this issue, 1992–1998
2 sentences

1998First, it must be considered whether the dragnet clause employed in the agreement is "boilerplate." The Stewart Court noted that "[o]ften these clauses are not discussed between the borrower and the lender so that the borrower is not aware of the existence or the effect of these clauses." Stewart, 608 So.2d at 1126 (citing United States v. American Nat'l Bank, 255 F.2d 504 (5th Cir.1958); Matter of Ladner, 50 B.R. 85 (Bankr.S.D.Miss.1985); First Sec.

1996First, it must be considered whether the dragnet clause employed in the agreement is "boilerplate." The Stewart Court noted that "[o]ften these clauses are not discussed between the borrower and the lender so that the borrower is not aware of the existence or the effect of these clauses." Stewart, 608 So. 2d at 1126 (citing United States v. American Nat'l Bank, 255 F.2d 504 (5th Cir. 1958); Matter of Ladner, 50 B.R. 85 (Bankr.

13
First Security Bank of Utah v. Shiewgreen
utah · 1980 · cited in 2 Mississippi opinions naming this issue, 1996–1998
2 sentences

1998Bank v. Shiew, 609 P.2d 952, 957 (Utah 1980); Underwood v. Jarvis, 358 So.2d 731 (Ala.1978); Mohler v. Buena Vista Bank & Trust Co., 42 Colo.App. 4 , 588 P.2d 894 (1978)).

1998Stewart, 608 So.2d at 1126 (citing Mark Twain Kansas City Bank v. Cates, 248 Kan. 700 , 810 P.2d 1154 (1991); Shiew, 609 P.2d at 957-58 ; Wong v. Beneficial Sav. and Loan Ass'n, 56 Cal.App.3d 286 , 128 Cal. Rptr. 338, 342 (1976)).

12
Newton County Bank, Louin Branch Office v. Jonesgreen
miss · 1974 · cited in 2 Mississippi opinions naming this issue, 1982–1995
2 sentences

1995Newton County Bank v. Jones, 299 So.2d 215, 219-20 (Miss. 1974); Holland v. Bank of Lucedale, 204 So.2d 875, 877 (Miss. 1967).

1982Newton County Bank, Louin Branch Office v. Jones, 299 So.2d 215 (Miss. 1974).

12
Whiteway Finance Co., Inc. v. Greengreen
miss · 1983 · cited in 2 Mississippi opinions naming this issue, 1992–1992
2 sentences

1992It is well settled within this jurisdiction that a dragnet clause is valid to encompass future debts that a borrower may incur, within the security agreement, Cochran v. Deposit Guaranty Nat'l Bank, 509 So.2d 1045 (Miss. 1987); Whiteway Finance Co., Inc., v. Green, 434 So.2d 1351 (Miss. 1983).

1992Dragnet clauses are valid and enforceable in Mississippi, Whiteway Finance Co. v. Green, 434 So.2d 1351, 1353 (Miss. 1983), if properly executed and stated in clear and unambiguous language.

12
Davis v. Crawfordgreen
miss · 1936 · cited in 2 Mississippi opinions naming this issue, 1974–1992
2 sentences

1974That Don Jones gave cattle as his collateral for the additional loans, which instruments were not signed by Myrtis Jones." (Emphasis added) The majority opinion says that this Court clearly indicated in Davis v. Crawford, 175 Miss. 493 , 168 So. 261 (1936) that if the dragnet clause had contained three little words "one of them" that the decision would have been in favor of Crawford, Receiver of the Bank, rather than the homeowners.

1974That Don Jones gave cattle as his collateral for the additional loans, which instruments were not signed by Myrtis Jones." (Emphasis added) The majority opinion says that this Court clearly indicated in Davis v. Crawford, 175 Miss. 493 , 168 So. 261 (1936) that if the dragnet clause had contained three little words "one of them" that the decision would have been in favor of Crawford, Receiver of the Bank, rather than the homeowners.

12
Singing River Mall Company v. Mark Fields, Inc.green
miss · 1992 · cited in 1 Mississippi opinions naming this issue, 1995–1995
1 sentence

1995Singing River Mall v. Mark Fields, Inc., 599 So.2d 938, 947 (Miss. 1992) (holding that contract modifications must "meet the requirements for a valid contract," presumably including new consideration).

11
Harris v. Griffithgreen
miss · 1968 · cited in 1 Mississippi opinions naming this issue, 1992–1992
1 sentence

1992See Harris v. Griffith, 210 So.2d 629 (Miss. 1968) (each word and clause throughout entire instrument should be reconciled and given meaning if reasonably possible).

11
Trapp v. Tidwellgreen
miss · 1982 · cited in 1 Mississippi opinions naming this issue, 1992–1992
2 sentences

1992Trapp v. Tidwell, 418 So.2d 786, 792 (Miss. 1982), citing Williams v. Life Ins.

1992Trapp v. Tidwell, 418 So.2d 786 , 792 (Miss. 1982), citing Williams v. Life Ins.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
United States v. American National Bank of Jacksonville and Title & Trust Company of Florida green
ca5 · 1958
2 sentences

1998First, it must be considered whether the dragnet clause employed in the agreement is "boilerplate." The Stewart Court noted that "[o]ften these clauses are not discussed between the borrower and the lender so that the borrower is not aware of the existence or the effect of these clauses." Stewart, 608 So.2d at 1126 (citing United States v. American Nat'l Bank, 255 F.2d 504 (5th Cir.1958); Matter of Ladner, 50 B.R. 85 (Bankr.S.D.Miss.1985); First Sec.

1996First, it must be considered whether the dragnet clause employed in the agreement is "boilerplate." The Stewart Court noted that "[o]ften these clauses are not discussed between the borrower and the lender so that the borrower is not aware of the existence or the effect of these clauses." Stewart, 608 So. 2d at 1126 (citing United States v. American Nat'l Bank, 255 F.2d 504 (5th Cir. 1958); Matter of Ladner, 50 B.R. 85 (Bankr.

31992–1998
Mohler v. Buena Vista Bank & Trust Co. green
coloctapp · 1978
2 sentences

1998Bank v. Shiew, 609 P.2d 952, 957 (Utah 1980); Underwood v. Jarvis, 358 So.2d 731 (Ala.1978); Mohler v. Buena Vista Bank & Trust Co., 42 Colo.App. 4 , 588 P.2d 894 (1978)).

1998Bank v. Shiew, 609 P.2d 952, 957 (Utah 1980); Underwood v. Jarvis, 358 So.2d 731 (Ala.1978); Mohler v. Buena Vista Bank & Trust Co., 42 Colo.App. 4 , 588 P.2d 894 (1978)).

21992–1998
Mark Twain Kansas City Bank v. Cates green
kan · 1991
2 sentences

1998Stewart, 608 So.2d at 1126 (citing Mark Twain Kansas City Bank v. Cates, 248 Kan. 700 , 810 P.2d 1154 (1991); Shiew, 609 P.2d at 957-58 ; Wong v. Beneficial Sav. and Loan Ass'n, 56 Cal.App.3d 286 , 128 Cal. Rptr. 338, 342 (1976)).

1998Stewart, 608 So.2d at 1126 (citing Mark Twain Kansas City Bank v. Cates, 248 Kan. 700 , 810 P.2d 1154 (1991); Shiew, 609 P.2d at 957-58 ; Wong v. Beneficial Sav. and Loan Ass'n, 56 Cal.App.3d 286 , 128 Cal. Rptr. 338, 342 (1976)).

21996–1998
Merchants Nat. Bank v. Stewart green
miss · 1992
2 sentences

1998Texie Rae Wallace argues that there is no mention of any specific antecedent debt in either of the assignments, and thus the bank wrongly assumed that the assignments allowed it to "dragnet" all debt, including that which existed before the assignments were executed. [7] She argues that this Court's holding in Merchants Nat'l Bank v. Stewart, 608 So.2d 1120 (Miss.1992) established the rule that antecedent debts will not be deemed within a dragnet clause unless they are specifically identified in the instrument.

1998First, it must be considered whether the dragnet clause employed in the agreement is "boilerplate." The Stewart Court noted that "[o]ften these clauses are not discussed between the borrower and the lender so that the borrower is not aware of the existence or the effect of these clauses." Stewart, 608 So.2d at 1126 (citing United States v. American Nat'l Bank, 255 F.2d 504 (5th Cir.1958); Matter of Ladner, 50 B.R. 85 (Bankr.S.D.Miss.1985); First Sec.

21996–1998
Coombs v. Wilson green
miss · 1926
2 sentences

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

21953–1953
Baker v. B. L. Ass'n of Jackson green
miss · 1934
2 sentences

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

21953–1953
Herron v. Land neutral
miss · 1929
2 sentences

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

1953Baker v. Building and Loan Association of Jackson, 168 Miss. 808 , 152 So. 288 (1934); Coombs v. Wilson, 142 Miss. 502 , 107 So. 874 (1926); Herron v. Land, 151 Miss. 893 , 119 So. 823 (1929).

21953–1953
Underwood v. Jarvis green
ala · 1978
1 sentence

1998Bank v. Shiew, 609 P.2d 952, 957 (Utah 1980); Underwood v. Jarvis, 358 So.2d 731 (Ala.1978); Mohler v. Buena Vista Bank & Trust Co., 42 Colo.App. 4 , 588 P.2d 894 (1978)).

11998–1998
Cochran v. Deposit Guar. Nat. Bank green
miss · 1987
1 sentence

1992It is well settled within this jurisdiction that a dragnet clause is valid to encompass future debts that a borrower may incur, within the security agreement, Cochran v. Deposit Guaranty Nat'l Bank, 509 So.2d 1045 (Miss. 1987); Whiteway Finance Co., Inc., v. Green, 434 So.2d 1351 (Miss. 1983).

11992–1992
Schenley Distillers, Inc. v. United States green
scotus · 1958
2 sentences

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85, 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank & Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir.1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85 , 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir. 1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

11992–1992
DeLucia v. United States green
scotus · 1958
2 sentences

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85, 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank & Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir.1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85 , 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir. 1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

11992–1992
American National Bank of Jacksonville v. United States green
scotus · 1959
2 sentences

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85 , 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir. 1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85 , 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir. 1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

11992–1992
Messervy v. Messervy green
sc · 1908
2 sentences

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85, 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank & Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir.1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

1992(T)he most important element for a Court to determine is: "What was the intention of the parties when they executed these various instruments?" Matter of Ladner, 50 B.R. 85 , 91 (Bankr.S.D.Miss. 1985); Mohler v. Buena Vista Bank Trust Co., 42 Colo. App. 4 , 588 P.2d 894 (1978); United States v. American National Bank, 255 F.2d 504 (5th Cir. 1958), cert. denied, 358 U.S. 835 , 79 S.Ct. 58 , 3 L.Ed.2d 72 , rehearing denied, 359 U.S. 1006 , 79 S.Ct. 1135 , 3 L.Ed.2d 1034 .

11992–1992
Amos v. Lance neutral
miss · 1978
1 sentence

1982In Amos v. Lance, 355 So.2d 84 (Miss. 1978), we held the failure to reduce an alleged deficiency to a liquidated claim or judgment could not be the sole basis for foreclosure of a deed of trust containing a dragnet clause.

11982–1982

Where else courts name it

GA 19 (1962–2025) MS 11 (1953–1998) MA 11 (1978–2015) CA 8 (1976–2024) WI 5 (1985–2025) FL 5 (1985–2021) IA 5 (1977–2021) TX 4 (1979–2019) KS 4 (1983–1995) IN 4 (1987–2006) AK 3 (1987–1993) WY 3 (1988–2026) IL 3 (1981–1997) AL 3 (1986–1991) TN 3 (2005–2019) UT 2 (1985–1995) NM 2 (1986–2012) ME 2 (1981–1998) AZ 2 (1986–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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