Sixth Circuit -- Nancy Dickson v. Countrywide Home Loans

Although lender did not have a perfected lien on manufactured home prior to foreclosure - as no notation was made to title and lis penden does not suffice - subsequent conversion to improvement to real estate perfected the claim.

A manufactured home is personalty, until converted to an improvement to real estate.

Petitoner can avoid the lien, however, since the operative act wasn't the mortgage (as the property was personalty at the time) but the (involuntary) state court default judgement, and all other requirements for avoidance are met.

Nancy Dickson v. Countrywide Home Loans