Have any court decisions applied UCC §9-307(h) to the United States or federal agencies (case law, dates)?

1. What §9-307 says and where it lives in the UCC

Article 9 of the Uniform Commercial Code governs secured transactions and §9-307 addresses the debtor’s “location” — the choice-of-law rule that determines which jurisdiction’s law governs perfection and priority questions — and the statutory text and commentary are published and summarized in public legal resources such as Cornell’s UCC pages and the broader Article 9 materials ^{[1] [2]}. State codes annotate and adopt §9-307 (for example, Ohio and New York reproductions of the rule appear in state compilations), demonstrating that §9-307 is implemented at the state level and therefore typically litigated in state court contexts ^{[6] [7]}.

2. Where one would expect to find decisions, and what the reporting shows

Research guides and primary-law collections maintained by law libraries and repositories compile UCC-related case law from federal and state courts, including district and appellate decisions, and those resources are the natural places to locate any precedential applications of §9-307 to unconventional parties ^{[3] [4]}. The reporting provided cites these research paths and state codifications but contains no example opinions, dates, or dockets in which a court applied subsection (h) of §9-307 to the United States or a federal agency ^{[3] [4]}.

3. Direct answer to the question: cases applying §9-307(h) to the United States or federal agencies (case law, dates)

Based solely on the supplied sources, there are no documented court decisions identified that apply UCC §9-307(h) to the United States or any federal agency; the materials include the statute’s text, state enactments, and guides to where caselaw is archived but do not present any such case names, opinions, or dates ^{[1] [6] [7] [3] [4]}. The eCFR excerpt references using UCC case law to interpret a regulatory definition in the limited “farm products” context, but it does not cite any decision holding the federal government subject to §9-307(h) ^[5].

4. Context, plausible reasons, and research next steps

The absence of a case in the provided reporting does not prove none exist; comprehensive case searching would require querying federal and state opinion databases, commercial legal research platforms, and the collections that index federal-agency litigation and sovereign-immunity questions — the same repositories the reporting points readers toward ^{[3] [4] [8]}. Additionally, practical and legal barriers could make such applications rare: Article 9 is state-based and §9-307 resolves choice-of-law among states, while suits seeking to bind the United States or a federal agency can raise sovereign-immunity, administrative-law, and federal-question issues that complicate straightforward application of a state UCC provision — a complexity noted indirectly in discussions of forum and relation-of-transaction analyses in state UCC commentary ^{[9] [1]}. For a definitive answer beyond the supplied materials, targeted searches of federal district and appellate opinions, the Federal Circuit and Federal Claims dockets, and annotated state reporters would be required ^{[4] [8]}.

5. Competing interpretations and where reporting hints at narrow uses

Some regulatory texts (for example the cited eCFR provision) expressly allow courts’ UCC interpretations to inform regulatory definitions in narrow statutory programs — a use that speaks to interpretive influence rather than judicial rulings directly subjecting federal entities to §9-307(h) — and therefore one should distinguish between courts’ use of UCC precedent as interpretive authority and courts applying §9-307(h) as binding law against the United States ^{[5] [1]}.