after-acquired property clause in Washington

7 Washington opinions name it 2 courts 1918–2008 0 in the last five years

The cases below were cited by Washington 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 (1)

Case	Followed	Cited
Erickson v. Wahlheimgreen wash · 1958 · cited in 2 Washington opinions naming this issue, 2008–2008 2 sentences 2008RCW 64.04-.070; see Erickson v. Wahlheim, 52 Wn.2d 15, 17, 319 P.2d 1102 (1958). 2008RCW 64.04-.070; see Erickson v. Wahlheim, 52 Wn.2d 15, 17, 319 P.2d 1102 (1958).	2	2

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (6)

Case	Cited	Years
In the Matter of Automated Bookbinding Services, Inc., Bankrupt. Finance Company of America v. Hans Mueller Corporation green ca4 · 1972 2 sentences 1981In distinguishing Brodie, the Talcott court found this difference "critical." In In re Automated Bookbinding Servs., Inc., 471 F.2d 546 (4th Cir. 1972), Automated had signed a chattel mortgage in favor of Finance Company of America (FCA), which included an after-acquired property clause, on November 20, 1968. 1981In distinguishing Brodie, the Talcott court found this difference "critical." In In re Automated Bookbinding Servs., Inc., 471 F.2d 546 (4th Cir.1972), Automated had signed a chattel mortgage in favor of Finance Company of America (FCA), which included an after-acquired property clause, on November 20, 1968.	1	1981–1981
Joe Heaston Tractor & Implement Co. v. Claussen green nm · 1955 1 sentence 1961It was so decided by the Supreme Court of New Mexico in Joe Heaston Tractor & Implement Co. v. Claussen, 59 N. M. 486, 489, 287 P. (2d) 57 : “In the present case the Heaston company, seller, only owned the property turned over to the buyer, Claussen, at the time the sale was consummated, and it is difficult to see how the seller could ‘retain’ title to property it did not then own.	1	1961–1961
Bank of California v. Clear Lake Lumber Co. green wash · 1928 2 sentences 1943Co., 146 Wash. 543 , 264 Pac. 705 , we enunciated the rule that the after-acquired property clause in a mortgage, covering property after acquired for use in connection with the mortgagor’s business, is valid and enforcible in accordance with its terms. 1943Co., 146 Wash. 543 , 264 Pac. 705 , we enunciated the rule that the after-acquired property clause in a mortgage, covering property after acquired for use in connection with the mortgagor’s business, is valid and enforcible in accordance with its terms.	1	1943–1943
Guaranty Trust Co. v. New York & Queens County Railway Co. green ny · 1930 2 sentences 1934Appellant also relies upon the case of Guaranty Trust Co. v. New York & Queens County Ry., 253 N. Y. 190 , 170 N. E. 887 , where the mortgage, by its terms, bound only the mortgaged corporation “and its succes 174 sors,” and did not include purchasers, or assigns, the court saying: “A covenant by a corporation for itself and ‘its successors’ is like a covenant by a natural person for himself, ‘his executors and administrators.’ ” Also, that “The problem to be solved is the effect to be given to a covenant so phrased in its application to a railroad succeeding through merger to the franchise o 1934Appellant also relies upon the case of Guaranty Trust Co. v. New York & Queens County Ry., 253 N. Y. 190 , 170 N. E. 887 , where the mortgage, by its terms, bound only the mortgaged corporation “and its succes 174 sors,” and did not include purchasers, or assigns, the court saying: “A covenant by a corporation for itself and ‘its successors’ is like a covenant by a natural person for himself, ‘his executors and administrators.’ ” Also, that “The problem to be solved is the effect to be given to a covenant so phrased in its application to a railroad succeeding through merger to the franchise o	1	1934–1934
Fosdick v. Schall green scotus · 1879 1 sentence 1918Fosdick v. Scholl, 99 U. S. 235, 251 ; Myer v. Car Co., 102 ,U. S. 1; Trust Co. v. Groome, 2 U. S. App. 95, 105, 1 C.	1	1918–1918
Central Trust Co. of New York v. Marietta & N. G. Ry. Co. neutral ca5 · 1891 1 sentence 1918Fosdick v. Scholl, 99 U. S. 235, 251 ; Myer v. Car Co., 102 ,U. S. 1; Trust Co. v. Groome, 2 U. S. App. 95, 105, 1 C.	1	1918–1918

Where else courts name it

WA 7 (1918–2008) CO 6 (1904–1997) NY 5 (1930–1977) OH 5 (1899–2024) NC 4 (1909–1997) MO 4 (1891–1935) OK 4 (1933–2012) TX 3 (1979–1986) FL 3 (1979–2022) AZ 2 (1977–1977) MN 2 (1937–1966) MD 2 (1929–2003) CA 2 (1988–1997) NE 2 (1921–2000)

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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