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Triffin v. Dillabough

Supreme Court of Pennsylvania
716 A.2d 605 (1998)


Stacey Dillabough and Robert Lynn (defendants) presented several stolen money orders for payment at Chuckie Enterprises, Inc. (Chuckie’s), in Pennsylvania. The money orders were printed by American Express Travel Related Services Company, Inc. (American Express) (defendant) and contained the pre-printed signature of American Express’s chairman. However, the money orders were blank as to the amount, sender, payee, and date. The backs of the money orders stated that the amount would not be paid if the orders had been altered or stolen or if an endorsement was missing or forged. Chuckie’s paid the face amounts of the money orders to Dillabough and Lynn. American Express refused to pay Chuckie’s for the money orders. Chuckie’s sold and assigned all of its rights and interest in the money orders to Robert Triffin (plaintiff). Triffin sued Dillabough, Lynn, and American Express. The trial court entered default judgments against Dillabough and Lynn. The trial court also held that the money orders were not negotiable instruments and entered judgment for American Express. The superior court reversed with respect to American Express, holding that the money orders were negotiable instruments and that Triffin had status as a holder in due course and could recover the face amounts of the money orders. American Express appealed.

Rule of Law


Holding and Reasoning (Newman, J.)

Dissent (Castille, J.)

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