Supreme Court of Iowa

Matter of Estate of Simpson

April 15, 1987403 N.W.2d 791

Summary

The court held that the relatedness rule applies to future-advances clauses in Article 9 security agreements. Because the loan evidenced by note eight was secured by real estate, did not refer to the prior security agreements, and differed materially from the other loans, it was not covered by the floating lien. The court therefore affirmed the district court's allocation of the estate's sale proceeds and unsold property.