Publication Date


Document Type

Survey Article


The decade of the eighties saw substantial ground gained and lost by both sides of the seemingly interminable tug of war between debtors and creditors concerning the collection of deficiencies following nonjudicial sales of personal property. The first movement in this contest for the nineties, Contestabile v. Business Development Corp., occurred only twelve days into the decade. Although debtors clearly gained ground in this initial skirmish, how much ground is unclear.