Trustmark Insurance v. Bank One, Arizona, NA

OPINION

GEMMILL, Judge.

¶ 1 If a banking customer sends a bank a letter of instructions requesting wire transfers of funds upon future occurrences of a specified balance condition in the customer’s account, does the letter of instructions constitute a “payment order” under Article 4A of Arizona’s Uniform Commercial Code (“UCC”)? 1 We address this question, and others, in this decision.

¶ 2 Bank One, Arizona, NA (“Bank One”) appeals from a jury verdict for Trustmark Insurance Company (“Trustmark”) on Trust-mark’s claim under Article 4A of the UCC and from the trial court’s award of attorneys’…