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Based on NJ Law, Court Allows Claims to Proceed Against a Bank for Moneys Stolen By Employee: DMDB Adults Inc. and DMDB Kids Inc. v. Bank of American Corp. d/b/a Bank of America

Posted in Breach of Contract, Breach of Fiduciary Duty, Conversion, Industry: banking, Justice Kapnick, Barbara R., New York, Summary Judgment, Uniform Commercial Code UCC

In an October 7, 2010 decision by Justice Kapnick the Court granted partial summary judgment to the defendant bank on claims brought by a customer stemming from the customer’s employee’s cashing forged checks. 

The former employee cashed almost $1 million of checks from two different corporate bank accounts. Citing New Jersey law, the Court granted the motion to dismiss some claims under NJ UCC 4-406(f) which provides a limited statute of limitations but let other claims continue because there was an issue of fact whether one of the plaintiffs had executed a contract with the bank. The Court also granted the motion to dismiss the fraud claims, but allowed the conversion claims to proceed because a bank may be held strictly liable under the UCC for conversation.

DMDB Adults Inc. and DMDB Kids Inc. v. Bank of American Corp. d/b/a Bank of America, Sup Ct, New York Count, October 7, 2010, Kapnick, J, Index No. 103977/09