Rcd Check Cashing & Financial Services, Inc. v. Emlenrich, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedSeptember 27, 2024
DocketA-0707-23
StatusUnpublished

This text of Rcd Check Cashing & Financial Services, Inc. v. Emlenrich, LLC (Rcd Check Cashing & Financial Services, Inc. v. Emlenrich, LLC) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rcd Check Cashing & Financial Services, Inc. v. Emlenrich, LLC, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0707-23

RCD CHECK CASHING & FINANCIAL SERVICES, INC.,

Plaintiff-Respondent,

v.

EMLENRICH, LLC,

Defendant-Appellant,

and

TWO BROTHERS DRYWALL, LLC, and JULIO C. ORELLANA BANEGAS,

Defendants. _____________________________

Submitted September 23, 2024 – Decided September 27, 2024

Before Judges Sabatino and Gummer.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-1695-21. Windels Marx Lane & Mittendorf, LLP, attorneys for appellant (Amanda A. Meehan and Mark A. Slama, on the brief).

Scott K. McClain (Merle Brown & Nakamura, P.C.), attorney for respondent.

PER CURIAM

The pivotal question in this case is whether plaintiff, a check-cashing

company, was a "holder in due course" of a check issued by defendant to a

construction firm, which plaintiff cashed for a principal of that firm. The

recipient of the check proceeds absconded with the funds and left the country.

Plaintiff sued the issuer and other defendants, seeking to be reimbursed the sums

that it had paid on the check.

After hearing testimony from the parties at a bench trial, the presiding

Law Division judge concluded that plaintiff was a holder in due course under

the Uniform Commercial Code ("UCC"), despite the fact that the name of the

payee listed on the check slightly varied from the actual name of the construction

firm that had been on file with plaintiff. The trial judge further concluded that

plaintiff's conduct in paying the check did not violate the Check Cashers

Regulatory Act ("CCRA"), N.J.S.A. 17:15A-47(a). The check issuer appeals.

For the reasons that follow, we affirm the trial court's decision.

I.

A-0707-23 2 The record presents the following pertinent facts and procedural history.

The Parties and the Issuance of the Check in Question

Plaintiff RCD Check Cashing & Financial Services, Inc. ("RCD") is

licensed by the New Jersey Department of Banking and Insurance to provide

check-cashing services. A large portion of its business relates to commercial

check cashing, primarily for contractors in the building trades who use the

service to access immediate liquidity to cover financial needs and avoid the

delay in bank processing.

The issuer of the check in question, defendant Emlenrich, Inc., is a New

Jersey limited liability company owned by Ricardo Hernandez, with property in

Matawan. Emlenrich's general contractor hired a firm named "Two Brother

Drywall, LLC"1 to complete various projects at the property. Julio C. Orellana

Banegas (known to the parties as "Orellana") was a principal of Two Brother,

and he is the person who cashed the check in question.

According to the trial testimony of other individuals, Orellana asserted

that Two Brother needed funds to obtain materials to complete its projects at the

property. He demanded payment of $195,000 from Emlenrich to secure the

1 Unless otherwise indicated, we shall refer to the firm as "Two Brother" for ease of discussion. A-0707-23 3 materials. To obtain a check from Emlenrich, Orellana allegedly promised

Emlenrich that he would not cash it until Two Brother completed the work at

the property and would use it only to prove to suppliers that Two Brother had

sufficient funds to pay for materials.

Hernandez authorized the issuance of the check, which was in the

requested amount of $195,000. It was signed by Hernandez's son, Lenny, who

was generally authorized to sign checks on behalf of Emlenrich. Hernandez

testified the check was intended as payment for the construction project and as

a deposit for an additional job.

Upon receipt of the requested check, made payable to "Two Brothers

LLC," and not "Two Brother Drywall LLC," Orellana promptly took the check

to RCD and presented it for payment in January 2021.

After inspecting the check in compliance with its company guidelines,

RCD cashed it, charging Two Brother a cashing fee of $1,462.50 as permitted

by law. Following this exchange, when RCD attempted to deposit the funds into

its bank account, payment was denied due to a "stop payment" Emlenrich had

put on the check after it had been cashed by RCD. Orellana, meanwhile, fled

the country with the proceeds in a stolen truck belonging to Hernandez.

This Lawsuit

A-0707-23 4 Having paid out the full amount of the check, RCD sought to be

reimbursed. RCD filed a five-count complaint in the Law Division against

defendants Emlenrich, Two Brother, and Orellana, asserting, among other

things, that it was entitled to be paid as a holder in due course under the UCC.

Emlenrich, meanwhile, denied liability. Among other things, it asserted that

RCD was not a holder in due course, and, further, that RCD did not comply with

the payee-verification standards mandated by the CCRA.

Two Brother and Orellana both defaulted. Following discovery,

Emlenrich moved for summary judgment and RCD cross-moved for summary

judgment.

In March 2023, a motion judge dismissed all but one of RCD's counts with

prejudice and otherwise denied the competing cross-motions for summary

judgment. The remaining claim the court reserved for trial was whether RCD

was a holder in due course under the UCC.

The case proceeded to a bench trial before a different judge. We

summarize key facets of the evidence.

RCD's Practices

Harkesh Thakur, the Vice President of RCD, testified that due to the

nature of RCD's business he cashes large checks regularly—those more than

A-0707-23 5 $5,000 are processed every day, and those over $100,000 are processed about

monthly. As a check-cashing service provider, RCD maintains a risk

management and compliance manual that outlines its policies and procedures,

including its obligations under the CCRA.

As recounted by Thakur, RCD maintains a corporate file for "Two Brother

Drywall LLC" with a corporate resolution authorizing certain persons to cash

checks issued to it. In addition, RCD had on file from Two Brother a completed

application for commercial check cashing, a security agreement, an IRS Form

SS-4 letter verifying Two Brother's tax identification number, and a filed

certificate of formation. RCD also possessed a copy of Orellana's driver's

license, Social Security card, and passport. However, RCD had no such

resolution or documents on file for "Two Brothers LLC."

Two Brother and RCD's Relationship

Two Brother began using RCD's services in spring 2018. Between then

and January 2021, RCD cashed nearly 600 checks, totaling several million

dollars, made payable to Two Brother. From February 2020 to January 2021,

Two Brother cashed at RCD at least eighteen checks made payable to Two

Brother from Emlenrich, ranging in amounts of $1,800 to $29,300 and totaling

$183,075 before the presentment of the $195,000 check at issue. None of these

A-0707-23 6 earlier checks were ever questioned by Emlenrich, and all were honored.

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