Computer Sciences Corp. v. Sci-Tek, Inc. (1976)
Citation: 367 A.2d 658 · Decided: December 2, 1976.
Source note (2026-10-18):
- Links on this page to
https://static.case.law/a2d/367/cases/0658-01.jsonare an (unofficial Caselaw Access Project copy, retrieved before 2026-10-18; host disallows automated access); no official or otherwise permitted full-text copy was located on 2026-10-18.
Facts
A sheriff sought direction about levying computers claimed under a master lease and transferred through related entities before levy. The court examined whether the lease was a true ownership arrangement or a security device and whether the debtor’s transfer was valid against the judgment creditor. Source: full opinion, Caselaw Access Project, re-read 2026-10-18.
Holding and reasoning
The nominal computer lease was a security arrangement, not a true lease. A secured interest did not itself prevent levy; the court applied Porter-Way and recognized the secured claimant’s priority in sale proceeds. However, the alleged pre-levy transfer raised a factual issue requiring an evidentiary hearing about fraud. The court did not finally hold every disputed computer subject to levy or extinguish a true third-party owner’s title. Source: opinion above; maryland-national-bank-v-porter-way-harvester-1972.
Practical scope and later treatment
Classification as a true lease or security interest and the validity of a transfer before
levy are separate from execution-sale priority. This opinion is verified later treatment
of Porter-Way, not a modern revised-Article-9 sale-title certification. No comprehensive
citator or subsequent disposition was established; good-law status remains
needs_verification. A later related federal litigation lead is not treated as an appeal
or affirmance of this ruling without a full procedural comparison.
Bounded final review (2026-10-18)
The full opinion (decided December 2, 1976) was re-read from the Caselaw Access Project copy of 367 A.2d 658; it cites Porter-Way for the levy rule and reserves jurisdiction for an evidentiary hearing on whether the equipment was transferred before the October 15, 1975 levy. Page pinpoints were removed. law.justia.com was not used. The Caselaw Access Project copy was saved before the site’s robots.txt (which disallows all automated access) came to this review’s attention; it is kept as evidence only and no further automated requests were made to static.case.law. Comprehensive later treatment remains needs_verification; no citator certification is made.
Applies in →
delaware, equipment-and-machinery, personal-property-execution-sales-by-state
Legal information, not legal advice. Verify against the current primary source before relying on this summary.