Issue: What question must be answered in order to reach a conclusion in the case? This should be a legal
question which, when answered, gives a result in the particular case. Make it specific (e.g. “Has there
been a false imprisonment if the plaintiff was asleep at the time of ‘confinement’?”) rather than general.
Most cases present one issue. If there is more than one issue, list all, and give rules for all issues raised.
Rule: The rule is the law which applies to the issue. It should be stated as a general principal, (e.g. A duty
of care is owed whenever the defendant should anticipate that her conduct could create a risk of harm
to the plaintiff.) not a conclusion to the particular case being briefed, (e.g. “The plaintiff was negligent.”)
Application: The application is a discussion of how the rule applies to the facts of a particular case. While
the issue and rule are normally only one sentence each, the application is normally paragraphs long. It
should be written debate -not simply a statement of the conclusion. Whenever possible, present both
sides of any issue. Do not begin with your conclusion. The application shows how you are able to reason
on paper and is the most difficult (and, on exams, the most important) skill you will learn.
Conclusion: What was the result of the case? With cases, the text gives you a background of the facts
along with the judge’s reasoning and conclusion. When you brief cases, you are basically summarizing
the judge’s opinion. With case problems, the editors have given you a summary of the facts of an actual
case, but have not given you the judge’s opinion. Your job is to act as the judge in reasoning your way to
a ruling, again using the IRAC format.
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Chapter Thirty-Three Liability of Parties
33-19
3Q 33-15
+-
on the front of the checks, as well as not spotting his own book checks that were larger in amounts. Furthermore, Victory did
keeper’s name and
for account number on the back of the checks not match is invoices for each check at the end of each month,
(which appeared far too many times and on various payees” checks When any check was created by Victory’s computer system, the
to be seen as regular by a non negligent business owner).
value of the check was automatically assigned to a general led
Further, there were inadequate checks and balances in Vic ger account before the check could be printed. The values in the
tory’s record keeping process. For example, Victory could have general ledger account could have been reconciled at the end of
ensured that it had an adequate segregation of duties, meaning each month with the actual checks and invoices. This would not
that more than one person would be involved in any control activ have been overly burdensome or costly because Victory already
ity. Here. Lunny exercised primary control over Victory’s bank Had the computer system that could do this in place. Based on
accounts. Another Victory employee, or Rosenfeld himself, could the foregoing the Court concludes that Victory is also thirty (30)
have reviewed Lumny’s work. In addition, Victory could have percent liable for the loss
increased the amount or authorization that was needed to per
form certain transactions. For example, any check that was over a For all the foregoing reasons, the Court finds that Wachovia is 70
threshold monetary amount would have to be authorized by more percent liable and Victory is 30 percent liable for the $188,273.00
than one individual. This would ensure an additional control on loss. Therefore, Victory Clothing Company is awarded $131,791.10.
()
happening without you being aware of the fact an employee Thus, if a bank pays a check that contains a forged
was forging checks on the company’s account.
indorsement, the bank has converted the check by wrong.
fully paying it. The bank then becomes liable for the face
Conversion Conversion of an instrument is an una amount of the check to the person whose indorsement was
thorized assumption and exercise of ownership over it. A forged (3-420). For example, Arthur Able draws a check
negotiable instrument can be converted in a number of for $500 on his account at First Bank, payable to the order
ways. For example, it might be presented for payment or of Bernard Barker. Carol Collins steals the check, forges
acceptance, and the person to whom it is presented might Barker’s indorsement on it, and cashes it at First Bank.
refuse to pay or might accept and refuse to return it. An First Bank has converted Barker’s property because it had
instrument also is converted if a person pays an instrument no right to pay the check without Barker’s valid indorse
to a person not entitled to payment-for example, if it comment First Bank must pay Barker $500, and then it can try
tains a forged indorsement.
to locate Collins to get the $500 back from her.
Revised Article 3 modifies and then expands the pre- As is true under the original version of Article 3, if a check
vious treatment of conversion and provides that the law contains a restrictive indorsement (such as “for depositor
applicable to conversion of personal property applies to “for collection) that shows a purpose of having the check
instruments. It also specifically provides that conversion collected for the benefit of a particular account, then any
occurs if(1) an instrument lacks an indorsement necessary person who purchases the check or any depositary bank or
for negotiation and (2) it is (a) purchased, (b) taken for payor bank that takes it for immediate payment converts the
collection, or (c) paid by a drawee to a person not entitled check unless the indorser receives the proceeds or the bank
to payment. An action for conversion may not be brought applies them consistent with the indorsement (3-206).
by (1) the maker, drawer, or acceptor of the instrumento In the case that follows, Jones . Wells Fargo Bank, the
(2) a payee or an indorsee who did not receive delivery court concluded that a depositary bank was liable for con-
of the instrument either directly or through delivery to an version when it paid it to someone not entitled to enforce
agent or copayee 13-4201
the check
Jones v. Wells Fargo Bank, N.A.
76 UCC Rep. 2d 529 (5th Cir. 2012)
In September 2006 Adley Abdulwahab (Wahab) opened a business cash management account on behalf of Financial Group wit Wells
Furgo Bank, NA Wahab along with Michael K. Wallets and Mh. Wallen, was an author and siger on the amount
On January 29, 2007 Wahab withdrew S/.701.250 from Winancial’s accountar Wells Fargo Post Oak Branch Houston. Wahab
sed the funds to buy a case check owe to Luba Lateef. Maha Late Shaled Lates, and Zahod Lorethe Late Later
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= Q 33-11
+ – .
legitimate checks to those vendors. She there would forge the signature of Victory’s owner, Mark Rosenfeld, as drawer on the front of the
check and then forget the indonment of the nintended powee (Victory Variows vendors) on the wse of the check. After wing the
indorsement of the paper, Lunny either indorsed the check with her name followed by her customer or referenced her amunt
umber following the forged indorsement. She then deposited the cheeks intoler permal count at Wachovia Bank
At the time of the fraud by La Wachowia’s policies and regulations regarding the acceptance of checks for deposit provided that
Check payable Baronale combedewted ONLY into a moral count with the same name.”
Rosenfeld reviewed the bank statements from Hudson Bank on a monthly basis. However, among other observable irregularities
he failed to detect thar Lahad forged his shure or approximately 200 check Nor did he have a procedure to match checks to
trrates.
Victory brought suit again Wachovia person to the Pyramid Commercial Code, claiming that Wachovia should be liable to
it for the croire amount of the losses it sustained by virtue of Law forgery scheme. Vicky coulded that Wachostahad failed to
exercise ordinary care in taking the instruments that were able to various businesses and allowing them to be deposited into Lum’s
personal account. It asserted that this was commercially unreasonable was contrary to achova’s wateral rules and regulations
and exhibited a lack of ordinary care, substantially contributing to the loss resulting from the frondUnder section 3-405 of the Code
in such cumstances, the persone bearing the buscas recover from the person failing to cure ordinary care to the deal there
to exercise ordinary care contributed to the ins
Wachovia de turn, argued that because my made the framedlewat check payable actual vendors of Victory with
the intention that the vendors not get paid. Vidary’s action against it should be barred by the fictitious payee rule set out in
Section 3-404. Because section 3-404 com a compare the negligence provision, the court also needed to decide whether it should be
applied in this case
()
Abrahamsen, Judge
The Fictitions Payee Rule
In 1990, new revisions to Articles 3 and 4 of the UCC were imple Lunny made the fraudulent checks payable to actual vendors of
mented (the revisions). The new revisions made a major change Victory with the intention that the vendors not get paid Wachovia
in the area of double forgeries. Before the revisions, the case law therefore argues that Victory’s action against it should be barred
,
was uniform in treating a double forgery case as a forged drawer’s by the fictitious payee rule under $ 3-404. Section 3-404 states, in
Signature case, with the loss falling on the drawee bank. The revi relevant part
sons, however changed this rule by shifting to a comparative fault
approach. Under the revised version of the UCC, the loss in dou
83-404. Impostors fictitious payees
(b) FICTITIOUS PAYEE-If a person whose intent deter-
ble forgery cases is allocated between the depositary and drawe
mines to whom an instrument is payable (section 3-110(a) or
banks based on the extent that cach contributed to the loss By
(b) does not intend the person identified as payee to have any
adopting a comparative full approach, classification of the doo
interest in the instrument or the person kentified as puyee of
ble forgery as either a forged signature or forged indorsement case
an instrument is a fictitious person, the following rules apply
is no longer necessarily determinative. Thus, under the revised until the instrument is negotiated by special indorsement
Code, a depositary bank may not necessarily escape liability in (1) Any person in possession of the instrument is its
double forgery situations, as they did under the prior law
holder
Specifically, revised 3405 of the UCC, entitled “Employer’s (2) An indorsement by any person in the name of the
Responsibility for Fraudulent Indorsement by Employee.” intro-
payee stated in the instrument is effective as the indorsement
duced the concept of comparative fault as between the employer
of the payee in favor of a person who, in good faith, pays the
of the dishonest employee/embezzler and the bank(s). This is the
instrument or takes it for value or for collection
section under which Victory sued Wachovia Section 3-405(b) The fictitious payee rule applies when a dishonest employee
states, in relevant part:
writes checks to a company’s actual vendors, but intends that
If the person paying the instrument or taking it for value or
the vendors never receive the money instead, the employee
for collection fails to exercise ordinary care in paying or tak
forges the names of the payees and deposits the checks at
ing the instrument and that failure substantially contributes
another bunk. Under section 3-404(b) of the UCC, the indose
to loss resulting from the fraud, the person bearing the loss
ment is deemed to be effective since the employee did not
may recover from the person failing to exercise ordinary care intend for the payees to receive payment. The theory under the
to the extent the failure to exercise
ordinary care contributed rule is that since the indorsement is “effective,” the drawee bank
to the loss
was justified in debiting the company’s account. Therefore, the
. ,
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Part Seven Commercial Paper
Q 33-18
+ – .
– The fraudulent checks were made payable to known vendors
of Victory in amounts that were consistent with previous legiti
mate checks to those vendors.
– Alter forging the indorsement of the payee, Lunny either
indorsed the check with her name followed by her account
number, or terrenced her account number following the
forged indorsement. All of the checks that were misappropri
ated had the same exact account number, which was shown on
the back side of the checks.
• About ten (10) out of approximately three hundred (300)
checks each month were forged by Lunny and deposited into
her personal account
• Rosenfeld reviewed his bank statements from Hudson Bank on
a monthly basis. Rosenfeld received copies or Victory’s can
celled checks from Hudson Bank on a monthly basis. However,
the copies of the cancelled checks were not in their normal
size, instead, they were smaller, with six checks (front and back
side) on each page
. The forged indorsements were written out in longhand, Le.. Lun
my’s own handwriting, rather than a corporate stamped signature.
• Victory did not match its invoices for each check at the end of
each month
• An outside accounting firm performed quarterly reviews
of Victory’s bookkeeping records and then met with
Rosenfeld. This review was not designed to pick up fraud or
misappropriation.
()
loss should fall on the company whose employee committed
the fraud
Revised UCC 3-404 changed the prior law by introducing
a comparative fault principle. Subsection (d) or 3404 provides
that if the person taking the checks fails to exercise ordinary care,
“The person bearing the loss may recover from the person fail
ing to exercise ordinary care to the extent the failure to exercise
Ordinary care contributed to the loss. Therefore, although the
fictitious payee rule makes the indorsement effective, the corpo
‘
rate drawer can shit the loss to any negligent bank, to the extent
that the bank’s megligence substantially contributed to the loss.”
Under the revised UCC, the drawer now has the right to see the
depositary bank directly based on the bank’s negligence. Under
the Old UCC, the fictitious payee rule was a “jackpot” defense for
depositary banks because most courts held that the depositary
bank’s own negligence was irrelevant. However, under revised
UCC 3404 and 3-405, the fictitious payee defense triggers
principles of comparative fault, so a depositary bank’s own negli
gence may be considered by the trier of fact. Therefore, based on
the foregoing reasons, the fictitious payee defense does not help
Wachovia in this case.
Allocation of Liability
As stated comparative negligence applies in this case because
of the revisions in the UCC. In determining the liability of
the parties, the Court has considered, inter alia, the following
factors
. At the time of the fraud by Lunny. Wachovia’s policies and
regulations regarding the acceptance of checks for deposit
provided that “checks payable to a non-personal payee can
be deposited ONLY into a non-personal account with the
same name.”
. Approximately two hundred (200) checks drawn on Victo
ry’s corporate account were deposited into Lunny’s personal
account at Wachovia
• The first twenty-three (23) fraudulent cheeks were made pay
able to entities that were not readily distinguishable as busi-
nesses, such as Sean John.” The check dated December 17,
2001, was the first fraudulent check made payable to a
payee that was clearly a business, specifically “Beverly Hills
Shoes, Ine.”
• Lunny had been a bookkeeper for Victory from approximately
1982 until she resigned in May 2003. Rosenfeld never had any
problems with Lunny’s bookkeeping before she resigned
• Lunny exercised primary control over Victory’s bank accounts.
• Between 2001 and 2003, the checks that were generated to
make payments to Victory’s vendors were all computerized
checks generated by Lunny. No other Victory employee other
than Lunny knew how to generate the computerized checks,
including Rosenfeld
Based on the foregoing the Court finds that Victory and
Wachovia are comparatively negligent. With regard to Wachovia’s
negligence, it is clear that Wachovia was negligent in violating
its own rules in repeatedly depositing corporate checks into Lunny’s
personal account at Wachovia Standard commercial bank proce
dures dictate that a check made payable to a business be accepted
only into a business checking account with the same title as the busi
ness. Hada single teller at Wachovia followed Wachovia’s rules, the
fraud would have been detected as early as December 17, 2001, when
the first fraudulently created son personal payee check was pre
sented for deposit into Lunny’s personal checking account. Instead
Wachovia permitted another one hundred and seventy-six (176)
checks to be deposited into Lunny’s account after December 17,
2001. The Court finds that Wachovia failed to exercise ordinary
cate, and that failure substantially contributed to Victory’s loss
resulting from the fraud. Therefore, the Court concludes that
Wachovia is seventy (70) percent liable for Victory’s loss
Victory on the other hand, was also negligent in its supervision
of Lunny, and for not discovering the fraud for almost a two year
period. Rosenfeld received copies of the cancelled checks, albeit
smaller in size, on a monthly basis from Hudson Bank. The cop
ies of the checks displayed both the front and back of the checks
Rosenfeld was negligent in not recognizing his own forged signature
i
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33-15
Part Seven Commercial Paper
= Q 33-16
+-
For example, Anderson, an accountant in charge of
accounts payable at Moore Corporation, prepares a false
invoice naming Parks Inc., a supplier of Moore Corpora
tion, as having supplied Moore Corporation with goods.
and draws a check payable to Parks for the amount of the
invoice. Anderson then presents the check to Temple, trea-
surer of Moore Corporation, together with other checks
with invoices attached. Temple signs all of these checks
.
and returns them to Anderson for mailing. Anderson then
withdraws the check payable to Parks. Anyone, including
Anderson, can negotiate the check by indorsing it in the
name of Parks Inc.
The rationale for the fictitious payee rule is similar
to that for the impostor rule. If someone has a dishot
est employee or agent who is responsible for the forgery
of some checks, the employer of the wrongdoer should
bear the immediate loss of those checks rather than some
other innocent party. In turn, the employer must locate the
unfaithful employee or agent and try to recover from him.
This outcome is consistent with other law referred to as
“respondeat superior,” under which principals bear respon
sibility for their agents
handling or processing checks should fall on the employer
rather than on the bank or other person that takes the check
or pays it(3-405). As to any person who in good faith pays
an instrument or takes it for value, a fraudulent indorse-
ment by a responsible employee is effective as the indorse-
ment of the payee if it is made in the name of the payee or
in a substantially similar name 3-405(b)). This means that
later takers get good title to the instrument. If the person
taking or paying the instrument failed to exercise ordinary
care and that failure substantially contributed to loss result-
ing from the fraud, the comparative negligence doctrine
guides the allocation of the loss
A fraudulent indorsement includes a forged indorsement
purporting to be that of the employer on an instrument
payable to the employer, it also includes a forged indorse-
ment purporting to be that of the payee of an instrument
on which the employer is drawer or maker (3-405(a)(2).
((.
“Responsibility with respect to instruments means the
authority to (1) sign or indorse instruments on behalf
of the employer, (2) process instruments received by the
employer, (3) prepare or process instruments for issue in
the name of the employer. (4) control the disposition of
instruments to be issued in the name of the employer, or
(5) otherwise act with respect to instruments in a respon
sible capacity. “Responsibility” does not cover those who
simply have access to instruments as they are stored or
transported, or that are in incoming or outgoing mail
13405(x3)
In the case that follows, Victory Clothing Co. Wachovia
Bank, NA, the court applied comparative negligence prin
ciples to split the loss between a company whose employee
forged checks and a depositary bank that allowed the
forger to deposit the checks to her own personal account in
violation of its own rules. As you read the case and note the
reasons the court gave for assigning 30 percent of the risk
to the employer, you might ask yourself whether the answer
would be different today when many banks no longer return
copies of canceled checks or even photocopies of them-
regularly to the customer. You might also ask yourself what
steps could be taken to prevent something like this from
()
Comparative Negligence Rule Concern-
ing Impostors and Fictitious Payees Revised
Article 3 also establishes a comparative negligence rule if
(1) the person, in a situation covered by the impostor or fic-
titious payee rule pays the instrument or takes it value
or collection without exercising ordinary care in paying or
taking the instrument and (2) that failure substantially con
tributes to the loss resulting from payment of the instrument
In these instances, the person initially bearing the loss may
recover an allocable share of the loss from the person who
did not exercise ordinary care 3-404(d)).
Fraudulent Indorsements by Employees
Revised Article 3 specifically addresses employer responsi
bility for fraudulent indorsements by employees and adopts
the principle that the risk of loss for such indorsements
by employees who are entrusted with responsibilities for
Victory Clothing Co. v. Wachovia Bank, N.A.
59 UCC Rep. 2d 376 (Penn. Ct. Com. Pl. 2006)
Victory Clothing Company maintained a corporate checking amount af Hudson Bank Jeannette Lamy was employed by Victory as
its office manager and bookker kvapimately 21 year she reigned on May 21/03. From Avgust 2007 through May 2003
Lunny deposited approximately 200 checks drawn on Victory’s corporate account forating S788,273 into her personal checking account
ar Wachowe Rank
Lammy’s scheme ile double
forgeries. She prepared checks in the company’s computer system and made theme payable to known
wwwdors of Victory (es. Adidas) to whom no money was actually cwedThe checks were for dollar amcam that were consistent with the
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Q33-5
Chapter Thirty
Three Liability of Parties
33-5
+ – .
On January 10, 2014, a consent judgment was approved by the court as to Incarry only. Upon agreement of the parties, judg
ment was granted in furor of the Lean Trust aga Irizarry for $6,084.12 plus interest plus the counts of the action. The
entry stated that, wept for the fing of a judgment les no executie wuld be issued if Inzurry paid $200 a month for
12 mm, at which time the account would be reviewed to win if the should be increased Dalested that if Irizarry
failed to submit a payment on time, the Loan This would have the right to commence to proceedings without further onder of
the court
That same day the Loa Trust fed & motion for summary judgment against Algame, stating that there were ne
material facts to the rigated as to Algame became he had admitted executing the note, the mote had plain language as to his lawing
and the damages were established by an affidavit showing the amount due to be $15,084.42 plus 51,584.68 in interest.
Algame opposed the motion for rummary judgment, arguing that he received no money for home here no student loans
he served only as a consigner, the fender had entendiman mard and satisfaction with the student, and the lender had not show the
loan to the student was collectible. He also contended that he was entitled to a notice of dishonor or a notice of protest before the more
holder could attempt to collect on the note upon Irizarry default.
The note explicitly stated that the loan proceeds would be used awy for educational expenses and that the comigner
would not receive any of the loan proceeds. It also led “shall not be recessary for you to resort to or exhaust your remedies against
other Borrower before calling upon any other burrower to make repayment. The signatories furthermore agreed that:
Each Borrower intends to be treated as a principal on the Application/Promissory Note and not as a surety. To the extent
the Borrower may be treated as a surety, such Borrower waives all notices to which such Borrower might otherwise be
entitled by such law, and all suretyship defenses that might be available to such Borrower.
The trial court awarded summary judgment to the Lo Trust, and Algae appealed.
()
Robb, Judge
Algahmee acknowledged that as the cosigner he received no
Algahmee’s arguments are without effect. A party signs an
proceeds while promising to pay the debt on the terms in the
instrument as an accommodation party where he signs for the note. The note reiterated that the promise was made by each
purpose of incurring liability without being a direct beneficiary and every borrower and cosigner, individually and collec-
of the value, which is given to benefit another when the instru- tively.” It was also explicitly agreed that Algahmee’s responsi
ment is issued. An accommodation party may sign as a maker or
bility for paying the loan was unaffected by the liability of any
Indorser (or drawer or acceptor) and is obligated to be in the
person to him
capacity in which he signs
Algahmee also agreed that the Loan Trust was not required
The note clearly states that Algahmee is primarily liable
to resort to remedies against the student before calling upon
without regard to the student’s Irizarry’s) ability to pay or
Algame to make payment. Exhaustion of remedies against the
the exhaustion of remedies against the student. The note also student was expressly not required. Algame contracted to be
plainly states that Algahmee’s responsibility for paying the loan treated as a principal on this Application/Promissory Note and
is unaffected by the failure to notify him when a required pay. not as a surety,” Algahmee waived all notices and suretyship
ment is missed, that a separate notice to the cosigner is not
defenses
required, and that notice to one borrower is notice to all bor- Furthermore, Algamee signed a notice to the cosigner which
rowers. It further specifies. “You will not be obligated to make provided: “You may be sued for payment although the person
any demand upon me, send me any notice, present this Applica. who receives the education is able to pay
tion/Promissory Note to me for payment or make any protest of
Article 3 of the UCC provides that the discharge of an obli-
non-payment to me before suing to collect on this application/
gation of one party to pay an instrument does not discharge
Promissory Note if I am in default, and to the extent permitted
the obligation of the indoner or accommodation party having
by applicable law. I hereby wave any right I might otherwise
recourse against the discharged party. Thus the Loan Trust
have to require such actions.”
could discharge Irizarry without discharging the cosigner,
In any event, the language of the note eliminated any fac.
Algahmee
tual dispute as to Algahmee’s argument that the cosigner is
not principally liable because he received no loan proceeds. Judgment for National Student Loan Trust affirmed
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