Meritor Savings, F.A. v. Duke

31 Va. Cir. 183, 1993 Va. Cir. LEXIS 177
CourtFairfax County Circuit Court
DecidedJune 15, 1993
DocketCase No. (Law) 115299
StatusPublished

This text of 31 Va. Cir. 183 (Meritor Savings, F.A. v. Duke) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meritor Savings, F.A. v. Duke, 31 Va. Cir. 183, 1993 Va. Cir. LEXIS 177 (Va. Super. Ct. 1993).

Opinion

By Judge Marcus D. Williams

This case was tried before the court on April 28, 1993, and is now before the court for decision. Based upon the evidence, the arguments of counsel, and the memoranda filed, the court makes the following findings.

Facts

The facts are set out in the parties’ briefs, memoranda, pleadings and by stipulation. Briefly stated, John V. Duke was a customer of Meritor Savings, F.A. On February 6, 1992, Duke appeared at Meritor and requested that the bank issue a teller’s check1 in the amount of $19,115.98 to PST, Ltd., drawn from funds in Duke’s savings account. A check was then issued by Meritor, drawn on its account with the Federal Home Loan Bank of Atlanta (hereinafter “FHLB”). The check was delivered to the payee by Duke. On February 7, 1992, Duke reappeared at Meritor and requested that the bank issue a stop payment order on the same check. In consideration for issuing the order, Meritor required Duke to execute an indemnity agreement dated February 7,1992. Meritor issued the stop payment order to FHLB and recredited [184]*184Duke’s account for the amount of the check. FHLB dishonored the check when presented by the payee. Sometime thereafter, an attorney notified Meritor and demanded that Meritor honor the dishonored check. On February 25, 1992, Meritor issued a replacement check drawn on its account with FHLB in the amount of $19,190.11, payable to PST, Ltd. On February 27, 1992, Meritor placed a hold on $10,859.38, which was the balance of Duke’s funds in his account with Meritor, and made a written demand on Duke for the remainder of the loss. When Duke refused to pay Meritor, this lawsuit followed. Meritor argues that the check issued by it on behalf of Duke was analogous to a certified or cashier’s check, and was not subject to countermand under the Virginia Uniform Commercial Code, Virginia Code §§ 8.1-101 et seq. (1950, as amended). According to Meritor, it agreed to issue a stop payment order as an accommodation to its customer, but, because the check is a cash equivalent, Meritor was “compelled” to honor the same when presented by the payee. Finally, Meritor asserts that the indemnity agreement releases it from all liability arising from the stop payment order and was intended to protect the bank from the very thing that occurred in this case.

In response, Duke argues that the check issued by Meritor was a teller’s check, not a cashier’s check. The distinction is significant in that the former is more like an ordinary check under the Code. Duke avers that like an ordinary check, a teller’s check is subject to a stop payment order by the customer because it is not accepted upon issuance. Thus, Duke maintains that Meritor was not obligated or compelled to honor the check upon presentment by the payee because it had not yet been accepted or certified. With regard to the indemnity agreement, Duke contends that Meritor either breached the contract by failing to perform as promised or is not entitled to indemnification because Duke’s performance was discharged by Mentor’s failure to satisfy a condition precedent, that is stopping payment of the check.

Conclusions of Law

I. Whether the teller’s check issued by Meritor at the request of Duke obligated Meritor to pay on the instrument over a subsequent stop payment order.

In order to determine whether the teller’s check issued by Meritor was an unconditional promise to pay by Meritor, it is necessary to determine the nature of the check involved in the present case. By [185]*185definition, a check drawn by a bank upon itself is a cashier’s check. In effect, the bank is the drawer and the drawee. Commercially, a cashier’s check, unlike an ordinary check, operates as an assignment of funds and is treated as a cash equivalent or substitute. Swiss Credit Bank v. Virginia Nat’l Bank-Fairfax, 538 F.2d 587 (4th Cir. 1976). The issuing bank is not free to refuse payment on such a check when it is presented for payment by the payee. Id. Further, under Va. Code § 8.4-403, a cashier’s check is not subject to countermand because it is deemed “accepted” by the mere act of its issuance. “Acceptance” is the “drawee's signed engagement to honor the draft as presented.” Va. Code § 8.3-410(1). In the case of a cashier’s check, the drawee is the issuing bank and the drawer.

However, a teller’s check is distinguishable from a cashier’s check. It is a check drawn by a bank on its account in another bank. For purposes of the Virginia Uniform Commercial Code, a “bank carrying an account with another bank” is a “customer.” Va. Code § 8.4-103(l)(e). The drawer bank as the customer may stop payment on its check prior to acceptance or certification. Va. Code § 8.4-403(1). As such, the drawer bank’s liability is not governed by Va. Code § 8.3-411 in that it was not “accepted” upon issuance by the drawer/customer bank like a cashier’ check.

In the present case, Duke purchased a teller’s check from Meritor. Meritor issued a check drawn on its account with the Federal Home Loan Bank of Atlanta (“FHLB”). At the request of Duke, Meritor agreed to issue a stop payment order on the check as a customer with FHLB. In accordance with the stop payment order, FHLB dishonored the check when presented for payment by the payee. Despite Meritor’s arguments to the contrary, the court concludes that the check issued by Meritor was a teller’s check that was not accepted or certified upon issuance or by the drawee, and was subject to countermand.

In support of its position, Meritor relies primarily on Guaranty Fed. Sav. & Loan v. Horseshoe Operating, 748 S.W.2d 519 (Tex. App. Dallas 1988), rev ’d on other grounds, 793 S.W.2d 652 (Tex. 1990),2 in which the court applied the “cash equivalent” theory to teller’s checks. [186]*186In that case, a payee sued the drawer bank that stopped payment on a teller’s check at the request of its customer. The court held that the drawer of the teller’s check had no right to stop payment because “business of this state is transacted with such checks with the expectation that they do represent cash.” Id. at 525. The court looked to other jurisdictions, found two different approaches to the treatment of teller’s checks, and concluded that because the evidence in that case indicated that Guaranty considered the teller’s check to be the equivalent of cash, the teller’s check was accepted for payment when issued and was not subject to countermand. But several jurisdictions have disagreed, finding a teller’s check and a cashier’s check to be two distinct negotiable instruments. Lo Monaco v. Belfiore, 175 A.D.2d 59, 572 N.Y.S.2d 315 (A.D. I Dept. 1991); Fur Funtastic, Ltd. v. Kearns, 104 Misc. 2d 1030, 430 N.Y.S.2d 27 (N.Y. City Civ. Ct. 1980); Rubin v. Walt Whitman Fed. Sav. & Loan Assoc., 21 U.C.C. 610 (N.Y. Sup. App. T. 1977); Bruno Collective Fed. Sav. & Loan Assoc., 147 N.J. Super. 115, 370 A.2d 874 (1977); Fulton Nat. Bank v. Delco Corp., 128 Ga. App.

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