Choice Escrow and Land Title, LLC v. BancorpSouth Bank
United States Court of Appeals for the Eighth Circuit
754 F.3d 611 (2014)
Choice Escrow and Land Title, LLC (Choice) (plaintiff) maintained an account at Bancorpsouth Bank (Bancorpsouth) (defendant). Bancorpsouth offered four security procedures to protect against fraud: a username and password for each online user; device authentication; dollar limits on transactions; and a dual-control system. The dual-control system required approval of two unique users to authenticate a payment order. Choice declined the dual-control security measure. A third party hacked into Choice’s online bank account and ordered a wire transfer of $440,000. Bancorpsouth processed the transfer. Choice brought suit against Bancorpsouth, seeking to recover the lost money. The district court granted Bancorpsouth’s motion for summary judgment. Choice appealed.
Rule of Law
Holding and Reasoning (Wollman, J.)
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