On April 18, 2000, Philip Purkett parked his car, on which he owed $213 in payments, in his garage and locked the garage. Later that night, TWAS, Inc., a vehicle repossession company, broke into the garage and repossessed the car without notice to Purkett. To get the car back, Purkett paid a $140 storage fee and signed a document stating that he would not hold TWAS liable for any damages.

Did TWAS and Key Bank violate Article 9 requirements on repossession? [Purkett v Key Bank USA, Inc., 2001 WL 503050, 45 UCC Rep Serv 2d 1201 (ND Ill)]

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