Cite as: 507 U. S. 447 (1993)
Thomas, J., dissenting
of the three essential elements of a choate lien: that it attach to specific property." Ibid. In rejecting the federal claim of priority, we found no need even to mention whether the debtor had acquired its property interest in the deposited funds before or after notice of the federal lien. If specific attachment is not required for the state lien to be "sufficiently choate," 377 U. S., at 359, then neither is specific acquisition.2
Like the majority's reasoning today, see ante, at 452, the Government's argument in Vermont rested in part on dicta from New Britain suggesting that "attachment to specific property [is] a condition for choateness of a State-created lien." Brief for United States in United States v. Vermont, supra, at 19. See New Britain, 347 U. S., at 86 ("[T]he priority of each statutory lien contested here must depend on the time it attached to the property in question and became choate") (emphasis added). New Britain, however, involved competing statutory liens that had concededly "attached to the same real estate." Id., at 87. The only issue was whether the liens were otherwise sufficiently choate. Thus, like Security Trust (and, in fact, like all of our cases before Vermont), New Britain provided no occasion to consider the necessity of attachment to property that was not specifically identified at the time the state lien arose.
2 Even assuming, as the majority does, that the debtor in Vermont acquired its interest in the bank account before the federal lien arose, the critical argument that we rejected in that case was the contention that the State's claim could not be superior unless the account had been "specifically identified" as property subject to the State's lien. 377 U. S., at 355. At the time of the federal filing, the debtor's interest in the bank account, like the McDermotts' interest in the property at issue here, could have been uncertain or indefinite from the creditors' perspective. Nevertheless, in both cases, the particular property was "known to be subject to the [state] lien," ante, at 451, n. 3, simply because that lien, by its terms, applied without limitation to all property acquired at any time by the debtor.
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