## Facts

- Danny and Carole Wilson entered into a master credit agreement with Missouri State Credit Union.
- The master agreement included a cross-collateralization (dragnet) term stating that property pledged as collateral for one loan would also secure other present or future debts owed to the credit union.
- The Wilsons later obtained an auto loan from the credit union to purchase a pickup truck and granted the credit union a security interest in the pickup truck.
- The Wilsons also opened a credit-card account with the credit union.
- The Wilsons defaulted on both the auto loan and the credit-card account.
- The credit union sent two separate notices advising the Wilsons of their right to cure the respective defaults.
- The Wilsons could not make the required payments and surrendered the pickup truck to the credit union.
- After receiving the truck, the credit union sent an additional notice addressing disposition of the truck and referencing only the auto loan.
- That disposition notice was defective because it stated the Wilsons had 15 days to cure to prevent sale, but the credit union sold the pickup truck after 11 days.
- The sale proceeds did not satisfy the full auto-loan balance, leaving a claimed deficiency.
- The credit union sued the Wilsons for (1) a deficiency judgment on the auto loan and (2) the balance due on the credit-card account.
- The trial court held the defective disposition notice barred the credit union from recovering the auto-loan deficiency, but entered judgment against the Wilsons on the credit-card debt.
- The Wilsons appealed, arguing that because the master agreement cross-collateralized both debts with the same collateral, the defective notice should also bar recovery of the credit-card debt.

## Issues

1. Whether a secured party’s defective notice of sale of consumer collateral, which bars a deficiency on the secured auto loan, also bars recovery of a separate credit-card debt that is allegedly secured by the same collateral under a master cross-collateralization agreement.

## Decision

- The court affirmed the judgment holding the Wilsons liable for the credit-card debt.
- The court agreed the defective disposition notice barred any deficiency claim tied to the pickup truck’s sale, but held that the notice defect did not eliminate the Wilsons’ personal liability on the separate credit-card obligation.
- The court treated the auto-loan deficiency action (a claim dependent on a compliant Article 9 disposition) as distinct from an action to collect the unpaid balance of a separate account.

## Legal Principles

- Under UCC Article 9 (as adopted in Missouri), after default a secured party may pursue cumulative remedies, including suing on the debt and enforcing its security interest in collateral.
- A secured party disposing of consumer goods collateral must provide a disposition notice that meets statutory timing and content requirements; failure to comply limits or bars a deficiency recovery connected to that disposition.
- A defect in the notice and sale process operates as a remedy limitation tied to the collateral disposition and resulting deficiency; it does not, by itself, cancel unrelated contractual payment obligations.
- A cross-collateralization clause can extend a security interest to additional debts, but it does not convert a notice-based bar to an auto-loan deficiency into a blanket bar against collecting on every obligation covered by the master agreement.

## Conclusion

Missouri State Credit Union v. Wilson holds that when a creditor sends a defective consumer-goods disposition notice and therefore cannot recover a deficiency on the collateralized auto loan after the truck is sold, that notice defect does not also bar the creditor from obtaining a money judgment on a separate credit-card debt, even if the parties’ master agreement states that the same collateral secures future obligations.


Missouri State Credit Union v. Wilson, 176 S.W.3d 182 (2005)