Farmers National Bank v. Green River Dairy, LLC, No. 40101, 2014 Ida. LEXIS 5 (Ida. Sup. Ct. Jan. 24, 2014)

(plaintiff, a bank, made 10 loans to defendant farming company  to support its dairy operation; the bank properly filed its financing statement and obtained a perfected security interest in the defendant farming company's dairy cows; defendant producers sold commodities, on credit, to the farming company and filed lien notices with the Secretary of State;  the farming company defaulted on its loans to the bank, and the bank took possession of the cows, selling them at auction; the producers claimed an interest in proceeds, arguing that the cows had consumed the liened agricultural products sold by the producers; the trial court granted relief to the producers, finding that their lien extended to the livestock; in reversing the trial court’s judgment, the Idaho Supreme court ruled that statutory liens on agricultural products created under I.C. § 45-1802 did not continue in the livestock that consumed the liened products; had the legislature sought to include livestock in the definition of “agricultural product” it could have done so).