Bank of Lyons v. State

In Bank of Lyons v. State (1966), 26 Ill. Ct. Cl. 104, the claim was made by a bank that held a security interest, identified on the certificate of title, to a motor vehicle as security on a loan to one of its customers. The customer defaulted on the obligations of the loan and applied to the Secretary of State for a duplicate certificate of title. Subsequent to the issuance of the duplicate, the bank obtained possession of the duplicate and the motor vehicle. The motor vehicle was later stolen from the bank's premises. The bank claimed that the Secretary's mistaken issuance of the duplicate caused the bank to lose the motor vehicle. The Court's opinion assumed negligence on the part of the Secretary, but held that the conduct of the Secretary was not the proximate cause of the bank's loss.