Barbara Branch and Alexis Branch Missouri Cases

The Central Trust Bank sued Barbara and Alexis Branch for a deficiency judgment after repossessing and selling their vehicle. The circuit court denied the Bank's petition, finding it failed to provide reasonable notification of the sale and incorrectly classified the dealers-only auction as a public sale. The Supreme Court of Missouri reversed the circuit court's judgment, holding that the Bank properly sent the post-sale explanation and that the dealers-only auction was a private sale, thus complying with statutory notice requirements. The cause was remanded for further proceedings.

The Central Trust Bank appealed a judgment in favor of Barbara and Alexis Branch regarding a deficiency judgment after the repossession and sale of their vehicle. The trial court found that the Bank failed to properly send a post-sale notice and that the pre-sale notice improperly stated the sale type. The Eastern District affirmed the trial court's judgment, concluding that the Bank failed to take additional reasonable steps to notify the Branches after the certified post-sale notice was returned unclaimed, thus failing to strictly comply with statutory notice requirements for a deficiency judgment.