Fidelity & Deposit Co. v. Bank of Bladenboro

596 F.2d 632, 26 U.C.C. Rep. Serv. (West) 135
CourtCourt of Appeals for the Fourth Circuit
DecidedApril 20, 1979
DocketNo. 78-1221
StatusPublished
Cited by1 cases

This text of 596 F.2d 632 (Fidelity & Deposit Co. v. Bank of Bladenboro) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fidelity & Deposit Co. v. Bank of Bladenboro, 596 F.2d 632, 26 U.C.C. Rep. Serv. (West) 135 (4th Cir. 1979).

Opinion

WINTER, Circuit Judge:

Clarendon Bank & Trust Company (CB&T) recovered from its insurer Fidelity & Deposit Company of Maryland (F&D) losses that CB&T sustained when it permitted its depositor Car Retailers to draw on drafts deposited to its account which were subsequently dishonored because the authority of the agent to draw them had been [634]*634revoked. Clarendon Bank & Trust v. Fidelity & Deposit Co. of Md., 406 F.Supp. 1161 (E.D.Va.1975). F&D, having paid the losses and having been subrogated to CB&T’s rights, sued various banks which had participated in the collection process asserting that their negligence in the collection process and in advising CB&T that the drafts were dishonored caused CB&T’s losses.1 The district court granted summary judgment for defendants ruling that in notifying Wachovia, its immediate transferor, of the delay in processing the items and in presenting the items for payment, Charlotte Federal Reserve was negligent but that CB&T’s contributory negligence barred it and its insurer from recovery. We affirm. We rule that under the facts of this case CB&T was contributorily negligent as a matter of law and was thereby barred, under what we perceive to be the applicable North Carolina law, from any recovery from defendants.

I.

Many of the facts of this case are set forth in the reported opinion of the district court in the previous case and we will not repeat all of them here. The case arises out of an arrangement under which Car Retailers financed its purchase of used cars at “wholesale,” which it thereafter sold to other dealers, by drawing drafts on Richardson’s Used Cars, Inc. (RUCI) “collectible through” Bladenboro and depositing them in its account in CB&T. Happily for Car Retailers but ultimately unhappily for CB&T, CB&T permitted Car Retailers immediately to draw against these drafts in payment of its purchases. RUCI provided Jules Williamson of Car Retailers blank forms in three parts. The first was a blank draft on RUCI’s account, “collectible through” Bladenboro. Williamson was authorized to sign the name of Jerry Richardson, the principal officer of RUCI, on the draft. The second part was for record purposes and the third part was an envelope, in which Williamson would place the titles to the cars being financed, to be mailed directly to Bladenboro.

When Car Retailers purchased a used car, it would give the seller a draft on its CB&T account. The seller would then forward the draft and the titles for the cars for which the draft was given in payment to CB&T. After May 1973, Car Retailers’ account with CB&T was in an overdraft position, so that when a draft on Car Retailers was presented CB&T would notify Car Retailers which would then make a deposit to its account to meet the draft. Included in these deposits would be the drafts drawn on RUCI. CB&T would “sight post” the deposits and issue CB&T treasurer’s checks in payment of the sellers’ drafts, delivering the titles to Car Retailers. Thus CB&T paid out its funds against the uncollected drafts on RUCI.

When CB&T received a draft on RUCI as part of a Car Retailers deposit, it would send the item to Riggs National Bank of Washington, D.C. since CB&T was not a member of the Federal Reserve System. Riggs National would forward the item to Wachovia, which would forward it to Charlotte Federal Reserve, which would forward it to Richmond Federal Reserve, which would send it to Bladenboro.

Effective January 1, 1974, RUCI (Richardson), at the instance of Bladenboro which concluded that the financing arrangement was getting out of hand, claims that it notified Car Retailers (Williamson) that his authority to draw drafts on RUCI was revoked although RUCI would honor [635]*635drafts drawn up to that date.2 Notice of any revocation of authority was not given to CB&T and Car Retailers (Williamson) did not observe any revocation. After January 1, 1974, Car Retailers (Williamson) continued to execute drafts on RUCI and it continued to deposit them to its account with CB&T and CB&T continued to pay against them. When drafts executed after January 1 reached Bladenboro, they were dishonored. For some unexplained reason,3 CB&T was not advised that these drafts were dishonored until the middle of January. By that time it had paid or committed for payment $347,163 for dishonored RUCI drafts. Unfortunately, when RUCI dishonored drafts drawn after January 1, 1974, Bladenboro sent most of the accompanying automobile titles to Car Retailers rather than to CB&T. As a consequence, CB&T was able to salvage only approximately $40,000 of its loss.

We have stated that, subsequent to May 1973, Car Retailers’ account with CB&T was in an overdrawn condition. The fact is that, as early as June 1973, CB&T’s head bookkeeper became concerned about the account because of its use of uncollected funds. In the late summer of that year, he expressed his concern to the branch manager of the branch where Car Retailers’ account was maintained. The branch manager began to monitor the account, and then the account was moved to CB&T’s head office in October 1973. In that same month, the head bookkeeper called the account to the attention of CB&T’s executive vice president because of the size of the account and Car Retailers’ use of uncollected funds. By November 1973, CB&T’s senior loan officer was also concerned about the overdrafts. At that time, CB&T placed a ten-day “hold” on Car Retailers deposits, the purpose of which was to restrict Car Retailers’ use of its deposits for ten days, the period that CB&T thought would be required to determine that they were paid and not returned to CB&T. But the “hold” was never observed and CB&T continued to pay against uncollected drafts until it received actual notice of the dishonor of the RUCI drafts.

II.

We approach our decision with full recognition that issues of negligence and contributory negligence are ordinarily not susceptible of summary adjudication. Nonetheless, Rule 56, F.R.Civ.P., applies to negligence actions, and if the requirements of the rule are met, i. e. that the material facts are not in dispute and one of the parties is entitled to judgment as a matter of law, summary judgment should be granted. Bland v. Norfolk & Southern Railroad Company, 406 F.2d 863 (4 Cir. 1969); Allen v. New York Central Railroad, 397 F.2d 257 (6 Cir. 1968); Stevens v. Howard D. Johnson Company, 181 F.2d 390 (4 Cir. 1950). We also keep fully in mind that this case was before the district court under its diversity jurisdiction and we must look to the law of North Carolina in deciding it. Fortunately our task in this regard is made easier by the fact that North Carolina has adopted the Bank Deposits and Collections provisions of the Uniform Commercial Code. See N.C.Gen.Stat. § 25-41-101 et seq.

As we view this record, we think that, under the facts here, CB&T was guilty of contributory negligence as a matter of law, thereby barring it from any recovery [636]*636from defendants.4

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596 F.2d 632, 26 U.C.C. Rep. Serv. (West) 135, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fidelity-deposit-co-v-bank-of-bladenboro-ca4-1979.