From Casetext: Smarter Legal Research

Weeks Office Products, Inc. v. Chemical Bank

Appellate Division of the Supreme Court of New York, First Department
Feb 4, 1992
180 A.D.2d 419 (N.Y. App. Div. 1992)

Opinion

February 4, 1992

Appeal from the Supreme Court, New York County (Irma Vidal Santaella, J.).


We agree with the IAS court that the Uniform Commercial Code was inapplicable to wire transfers prior to the enactment of article 4-A (see, Bradford Trust Co. v. Texas Am. Bank, 790 F.2d 407; Evra Corp. v. Swiss Bank Corp., 673 F.2d 951, cert denied 459 U.S. 1017; Delbrueck Co. v. Manufacturers Hanover Trust Co., 609 F.2d 1047), and that defendant's reliance on UCC 4-406 (4) as a one-year time bar to the action is therefore unavailing.

Article 4-A, which provides for a similar one-year limitation period (UCC 4-A-505), cannot be applied retroactively as a matter of law (Banque Worms v. BankAmerica Intl., 77 N.Y.2d 362). Plaintiff, a non-moving party before the IAS court, urges that it should be granted summary judgment upon a search of the record on appeal. Defendant not having had an opportunity to respond to such application before the Motion Court, it would be inappropriate to entertain such request at this juncture, particularly since discovery is still being conducted relative to possible defenses which may be available to defendant bank. (See, prior decision at 169 A.D.2d 560.)

Concur — Rosenberger, J.P., Ellerin, Wallach, Smith and Rubin, JJ.


Summaries of

Weeks Office Products, Inc. v. Chemical Bank

Appellate Division of the Supreme Court of New York, First Department
Feb 4, 1992
180 A.D.2d 419 (N.Y. App. Div. 1992)
Case details for

Weeks Office Products, Inc. v. Chemical Bank

Case Details

Full title:WEEKS OFFICE PRODUCTS, INC., Respondent, v. CHEMICAL BANK, Appellant, et…

Court:Appellate Division of the Supreme Court of New York, First Department

Date published: Feb 4, 1992

Citations

180 A.D.2d 419 (N.Y. App. Div. 1992)

Citing Cases

Sinclair Oil Corp. v. Sylvan State Bank

The question whether the UCC applies to electronic fund transfers (EFTs) has not been addressed in Kansas.…

Galasso, Langione, & Botter, LLP v. Galasso

In its third cause of action in the Escrow Action, the Firm claims that: Signature never notified it of the…