In re Printz, 478 B.R. 876 (Bankr. D. Ill. 2012)

(grain elevator purchased grain and set-off funds due for corn and soybean purchase contracts to pay for farm inputs purchased by debtor; secured creditor of earlier perfected input liens claimed superior interest to funds in debtors’ Chapter 11 proceedings due to first perfected security interest in crops; elevator claimed Food Security Act of 1985 applied and changed the result because elevator was buyer in ordinary court and purchased grain free and clear of lien; court held creditor failed to comply with FSA procedure to protect state law liens because creditor’s notices to elevator failed to include debtor’s social security numbers and proper description of crops subject to creditor’s security interest; complete and precise compliance with notice provisions required; elevator, however, received entitled to receive only farm products but not proceeds from products; allowing elevator to use FSA to setoff preexisting debt and take priority over perfected liens would circumvent state laws on security instruments and is not permitted under FSA; elevator argued contract with debtor had right to set-off and prohibited assignment, so contract gives priority rights to elevator over creditor’s lien; court held creditor was never assignee on contract because creditor’s security interest arose in earlier agreement with debtors before accounts receivables from crops purchase contracts were formed; court declined to award pre-judgment interest to creditor because no debtor-creditor relationship was formed with elevator to permit interest award under state statute).