Security Bank & Trust Co. v. Federal National Bank & Trust Co. of Shawnee

554 P.2d 119, 19 U.C.C. Rep. Serv. (West) 211
CourtCourt of Civil Appeals of Oklahoma
DecidedApril 13, 1976
Docket48672
StatusPublished
Cited by14 cases

This text of 554 P.2d 119 (Security Bank & Trust Co. v. Federal National Bank & Trust Co. of Shawnee) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Security Bank & Trust Co. v. Federal National Bank & Trust Co. of Shawnee, 554 P.2d 119, 19 U.C.C. Rep. Serv. (West) 211 (Okla. Ct. App. 1976).

Opinions

BACON, Presiding Judge.

This appeal involves the issue of whether appellant bank gave sufficient notice of [121]*121dishonor of a check (check number 655) within its statutory midnight deadline. Appellant gave oral (telephone) notice of dishonor and appellee contends written notice was required. Both paities moved for summary judgment on stipulated facts. The trial court found oral notice was insufficient and sustained appellee’s motion for summary judgment.

The parties stipulated to the following facts:

“1. That with respect to check number 655, dated September 18, 1974, in the sum of $9,310.40:
(a) That check no. 655 was initially presented to the Federal Reserve Bank on Friday, September 20, 1974.
(b) That it was picked up by Mistletoe Express at approximately 9:00 p. m. on September 20,1974.
(c) That it was delivered to defendant bank [appellant] on Saturday, September 21,1974, before 6:30 a. m.
(d) That defendant gave the Federal Reserve Bank telephone notice of dishonor of said check on Tuesday, September 24, 1974.
(e) That check no. 655 was mailed by defendant to the Federal Reserve Bank on September 24, 1974, and received by the Federal Reserve Bank on September 25, 1974.
(f) That check no. 655 was presented to the Federal Reserve Bank the second time on Monday, October [sic] 30, 1974.
(g) That it was picked up by Mistletoe Express at approximately 9:00 p. m. on September 30, 1974.
(h) That it was delivered to defendant bank on Monday, October 1,1974.
(i) That defendant gave telephone notice of dishonor to the Federal Reserve on Tuesday, October 2, 1974.
(j) That check no. 655 was mailed by defendant to the Federal Reserve Bank on Tuesday, October 2, 1974, and received by the Federal Reserve Bank on Wednesday, October 3,1974.”

Based upon the above-stipulated facts, depositions and evidence, the trial court made the following finding in its journal entry:

“The Court further finds based on evidence presented herein as to Check No. 655, the following:
“(1) That Monday, September 23, 1974, was the banking day of receipt for purposes of determining whether or not defendant acted within its midnight deadline; that Saturday, September 21, 1974, was not a ‘banking day’ based on the facts established in this case; that defendant bank acted within its midnight deadline.
“(2) That defendant bank complied with all the terms and provisions of 12A O.S. (1971) Section 4-301 except that portion of said statute under (l)(b) to-wit: that defendant bank failed to send written notice of dishon- or or nonpayment as required by said statute; specifically the Court finds that oral telephone notice of dishonor and nonpayment given by defendant Bank prior to its midnight deadline on both occasions that check number 655 was presented is insufficient and fails to comply with 12A O.S. (1971) Section 4-301 and the Operating Letters of the Federal Reserve Bank of Kansas City.
“(3) That defendant bank is liable and accountable to plaintiff bank for check number 655 in the sum of $9,-310.40.
“The Court further finds that plaintiff claims attorney fees in its Petition, pursuant to Title 12 O.S. Section 936; that the Court finds that this cause of action falls under said statute and that attorney fees in the amount of $1500.xx should be awarded plaintiff.”

Appellee states the question to be decided is “whether telephonic notice was authorized under the applicable Oklahoma [122]*122law and the Operating Letters of the Federal Reserve Bank.”

Before we can determine if appellant’s telephonic notice of dishonor was sufficient, we must first determine if appellant “acted” within its midnight deadline. We say this because if appellant acted after the midnight deadline, oral or written notice would not be sufficient in this case. This issue was not raised until appellee did so in the last proposition of its answer brief.

The check in question was received by appellant on Saturday, September 21, 1974, and appellant telephoned notice of dishonor on Tuesday, September 24, 1974. The Uniform Commercial Code 12A O.S.1971 § 4-3011 gives appellant until its midnight deadline in which to dishonor an item. 12A OS.1971 § 4-104(1) (h) defines “midnight deadline” as follows:

“ ‘Midnight deadline’ with respect to a bank is midnight on its next banking day following the banking day on which it receives the relevant item or notice or from which the time for taking action commences to run, whichever is later.”

Section 4 — 104(1) (c) defines “banking day” as follows:

“ ‘Banking day’ means that part of any day on which a bank is open to the public for carrying on substantially all of its banking functions.”

The Uniform Commercial Code Comment following these sections states:

“Purposes:
1. Subsection (l)(c): ‘Banking Day.’ Under this definition that part of a business day when a bank is open only for limited functions, e.g., on Saturday evenings to receive deposits and cash checks, but with loan, bookkeeping and other departments closed, is riot part of a banking day.”

It is undisputed that on the Saturday in question only appellant’s “paying and receiving” departments were open. All other departments, including bookkeeping, accounting, installment loan, and proofing were closed. We therefore conclude under these circumstances that the Saturday in question was not a banking day as defined under the above-quoted Oklahoma law. Since the following Monday (September 23, 1974) would be the day of receipt of the item, appellant’s “midnight deadline” (as above defined) would be midnight of the next day, that is, midnight Tuesday, September 24, 1974. Appellant gave telephonic notice of dishonor on this Tuesday before midnight. We therefore conclude that appellant acted or telephoned notice of dishonor before its “midnight deadline,” when it telephoned the Federal Reserve on Tuesday, September 24, 1974. There is no question as to whether appellant “telephoned” before its midnight deadline after [123]*123the second presentment of the check. We say this because the check was delivered to appellant on Monday, October 1, 1974, and appellant “telephoned” the Federal Reserve on Tuesday, October 2, 1974.

We will now turn to the main issue of this case, which, as stated by appellee, is “whether telephonic notice was authorized under the applicable Oklahoma law and the Operating Letters of the Federal Reserve Bank.” No case deciding this issue has been brought to our attention, nor has our research disclosed one.

We think the positions of the parties can be fairly summarized and stated as follows. Appellee’s position is that notice of dishon- or by a payor bank must be in writing as required under 12A O.S.1971 § 4-301.

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Security Bank & Trust Co. v. Federal National Bank & Trust Co. of Shawnee
554 P.2d 119 (Court of Civil Appeals of Oklahoma, 1976)

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Bluebook (online)
554 P.2d 119, 19 U.C.C. Rep. Serv. (West) 211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/security-bank-trust-co-v-federal-national-bank-trust-co-of-shawnee-oklacivapp-1976.