In Commercial National Bank v. McWilliams, 270 Ark. 826, 606 S.W.2d 363 (Ark. 1980), the Arkansas Supreme Court sided with a lienholder against a downstream purchaser who had purchased a motor home in a different state from the one in which the lienholder had perfected its interest. Id. at 365. In McWilliams, however, the purchaser did not rely on a clean certificate of title. Id. Although the purchaser was eventually able to procure a clean certificate of title, he did not do so until after the lienholder had brought a legal action seeking to foreclose its lien. Id. Because the purchaser had not relied on the issuance of a clean certificate of title, he did not qualify as a bona fide purchaser under U.C.C. Article 9. Id.