Judge Lawrence Kahn
Registration certifications accompanied 58 dairy cows Angell sold the debtors in 2006. A Security Agreement granted Angell a security interest in the cows, while a Financing Statement named her the secured party, and the 58 cows as collateral. Both statements listed an ear tag number for each cow, but Angell did not know which tag number corresponded to which cow. After the debtors auctioned 80 cows Angell was paid $27,764, for 22 cows identified from the registration certificates. She sought the unpaid balance for the cows sold in 2006. At issue before bankruptcy court was Angell's security interest in 16 cows, 10 of which lacked ear tags, and the other six bore tags that did not match numbers listed in the Security Agreement and Financing Statement. Looking to the Uniform Commercial Code and drawing on cases from Vermont and Wisconsin, bankruptcy court held she had such an interest. District court vacated on appeal. In addition to finding the utility of ear tags for identification purposes "inherently temporary" the court found no evidence supporting bankruptcy court's conclusion that registration certificates permitted trustee Collins to "readily and easily ascertain which cows were covered by the security interest."