State Bank of Cherry v. CGB Enterprises, Inc., 2013 IL 113836

State Bank of Cherry held a security interest in Rogowski crops and crop proceeds; lien attached to Rogowski’s crops.
CGB Enterprises bought Rogowski’s crops and received proceeds paid to Rogowski, not the bank.
Direct notices of security interest were sent in 2005 and 2006 under the Food Security Act, but county location was not listed.
Notices included a general assertion that the security interest covered all farm products; the location field was left blank.
Circuit court granted summary judgment for the bank; appellate court reversed, requiring strict compliance under the Act.
This Court adopts Farm Fresh Catfish and holds strict compliance is required for direct notice under § 1631(e).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether direct notice under § 1631(e) requires strict or substantial compliance.	State Bank urged substantial compliance suffices.	CGB urged strict compliance is required.	Strict compliance required.

Farm Credit Midsouth, PCA v. Farm Fresh Catfish Co., 371 F.3d 450 (8th Cir. 2004) (direct-notice strict-compliance standard under § 1631(e))
In re Printz, 478 B.R. 876 (Bankr. C.D. Ill. 2012) (weight of authority favoring strict compliance)
Lisco State Bank v. McCombs Ranches, Inc., 752 F. Supp. 329 (D. Neb. 1990) (direct-notice sufficiency questioned; strict compliance favored in some views)
People’s Bank v. Bryan Brothers Cattle Co., 504 F.3d 549 (5th Cir. 2007) (central filing context; not directly controlling direct-notice standard)
First National Bank v. Effingham-Clay Service Co., 261 Ill. App. 3d 890 (1994) (Illinois appellate view prior to Fed. Farm Fresh framework)
Farm Fresh Catfish Co. v. Farm Credit, 371 F.3d 450 (8th Cir. 2004) (controlling federal precedent demanding strict direct-notice compliance)
Sprietsma v. Mercury Marine, 537 U.S. 51 (2002) (interpreting uniformity in applying federal statutes)