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Falk v. Northern Trust Co.

Appellate Court of Illinois
763 N.E.2d 380 (2001)


Patricia Podmokly worked as a personal assistant to Ralph Falk II (plaintiff). Podmokly was a signatory on Falk’s accounts at Northern Trust Company (Northern) (defendant), and Northern knew that Podmokly acted as a fiduciary with respect to Falk. Over several years, Podmokly misappropriated more than $2,000,000 from Falk’s accounts at Northern. Falk sued Northern, claiming that Northern acted in bad faith by failing to investigate and notify Falk of Podmokly’s actions. Falk argued that Northern was placed on notice of Podmokly’s fraud because Podmokly used some of the funds obtained from Falk’s account to pay off a loan with Northern and also deposited funds drawn from Falk’s account into her personal account at Northern. Northern moved to dismiss the complaint because Falk did not bring the complaint within one year after receiving a bank statement showing an unauthorized signature or alteration. The circuit court found that Falk’s action was time barred and dismissed the complaint. Falk appealed.

Rule of Law


Holding and Reasoning (Hall, J.)

Dissent (Cerda, J.)

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