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First Financial Bank, N.A. v. Citibank, N.A.

2012 WL 3065546 (2012)

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First Financial Bank, N.A. v. Citibank, N.A.

United States District Court for the Southern District of Indiana

2012 WL 3065546 (2012)

Facts

A client hired attorney Misty McDonald to collect a debt from Accurate Manufactured Products Group, Inc. (AMPG). AMPG gave McDonald a cashier’s check for nearly $300,000 from Citibank, N.A. (defendant), which McDonald deposited at First Financial Bank, N.A. (plaintiff). First Financial endorsed the check and sent it to Chase bank electronically for processing. The next day, Chase presented the check to Citibank, but the account number was not valid. Claiming First Financial’s endorsement was illegible, Citibank sent the nonpayment notice to Chase through the Electronic Advanced Return Notification System (EARNS). Chase received the notice the next morning and sent letters notifying First Financial by mail. Meanwhile, McDonald wired funds from her First Financial account to China. First Financial tried to reverse the wire, but the funds had already been paid out. First Financial sued Citibank, claiming it violated check-processing rules under Regulation CC of the Expedited Funds Availability Act and requested summary judgment holding Citibank liable for the loss.

Rule of Law

Issue

Holding and Reasoning (Lawrence, J.)

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