The Supreme Court of Pennsylvania split on the question of when the Deficiency Judgment Act places a debtor's personal property offered as collateral beyond the reach of a judgment creditor when the agreement between the parties can be interpreted under either Article Il or Article IX of the Uniform Commercial Code.
Horbal v. Moxham Nat'1 Bank, 697 A.2d 577 (Pa. 1997).
David C. Bruening,
Uniform Commercial Code - Article III - Article IX - Status of Personal Property Used as Collateral - Deficiency Judgment Act,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol36/iss3/7