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Reid v. Key Bank of Southern Maine

821 F.2d 9 (1987)

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Reid v. Key Bank of Southern Maine

United States Court of Appeals for the First Circuit

821 F.2d 9 (1987)

Facts

Paul Reid and Depositors Trust Company of Southern Maine (bank), the predecessor in interest of Key Bank of Southern Maine, Inc. (defendant), had a long-standing and mutually profitable debtor-creditor relationship. All of the loan instruments generated by this relationship specified certain conditions that would entitle the bank to demand immediate repayment. Reid relied on his credit line to finance and expand his painting business. In March 1979, the bank raised Reid’s credit limit. Reid borrowed against his extended credit line to finance a new project. Two months later, the bank cut off Reid’s credit line without explanation. The bank later claimed it gave Reid prior notice of its decision, but Reid claimed he did not discover his loss of credit until September 1979. Reid’s business collapsed when he ran out of money, triggering a host of disastrous consequences. Reid sued the bank on 17 counts. The federal district-court jury ruled for the bank on all but Reid’s charge that the bank violated the implied covenant of good faith and fair dealing. Both parties appealed to the First Circuit.

Rule of Law

Issue

Holding and Reasoning (Bownes, J.)

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