Cite as: 507 U. S. 447 (1993)
Opinion of the Court
The argument of the United States that we rejected in Vermont was the contention that a state lien is not perfected within the meaning of New Britain if it "attach[es] to all of the taxpayer's property," rather than "to specifically identified portions of that property." 377 U. S., at 355 (emphasis added).3 We did not consider, and the facts as recited did not implicate, the quite different argument made by the United States in the present case: that a lien in after-acquired property is not "perfected" as to property yet to be acquired.
The Bank argues that, as of July 6, 1987, the date it docketed its judgment lien, the lien was "perfected as to all real property then and thereafter owned by" the McDermotts, since "[n]othing further was required of [the Bank] to attach the non-contingent lien on after-acquired property." Brief for Respondent 21. That reflects an unusual notion of what it takes to "perfect" a lien.4 Under the Uniform
"attach[ed] to specifically identified portions of that property," United States v. Vermont, 377 U. S., at 355 (emphasis added).
3 The dissent claims that "the Government's 'specificity' claim rejected in Vermont is analytically indistinguishable from the 'attachment' argument the Court accepts today," since "[i]f specific attachment is not required for the state lien to be 'sufficiently choate,' then neither is specific acquisition." Post, at 459 (citation omitted). But the two are not comparable. Until the debtor has acquired the subject property, it is impossible to say that "the property subject to the lien [has been] . . . established," United States v. New Britain, 347 U. S. 81, 84 (1954). Judicial attachment, on the other hand (and it is important to note that judicial attachment of the property, rather than attachment of the lien to the property, was what the Government's argument in Vermont involved), merely brings into the custody of a court property that is already—prior to judicial attachment— known to be subject to the lien.
4 The dissent accepts the Bank's central argument that perfection occurred when "there was 'nothing more to be done' by the Bank 'to have a choate lien' on any real property the McDermotts might acquire." Post, at 457-458 (quoting United States v. New Britain, supra, at 84); see also post, at 461. This unusual definition of perfection has been achieved by making a small but substantively important addition to the language of New Britain. " '[N]othing more to be done . . . to have a choate lien' "
451
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