Mobile Goods Ruling Reversed by Court of Appeals

The US Court of Appeals for the 3rd Circuit reversed the holding of the US District Court for the Middle District of Pennsylvania in In re Varsity Sodding Service Inc. (1998). The case concerns the UCC definition of mobile goods contained in Section 9-103(3). The district court found that for goods to be mobile goods under Section 9-103, they must be of a type that either would quite ordinarily be located in several states over the course of a given week or be such large and expensive pieces of equipment that the economic investment in them would necessitate their use over the broadest possible geographic area. In reversing the lower courts, the court of appeals applied the same definition of mobile goods as the lower courts but, obviously, reached a different conclusion.