NBT Bank v. First National Community Bank

MEMORANDUM

VANASKIE, Chief Judge.

At issue in the present case on cross-motions for summary judgment is whether an encoding error by Defendant First National Community Bank (FNCB) converted an otherwise timely return of a check under the Uniform Commercial Code’s “midnight deadline rule” into an untimely return, thereby making FNCB accountable to Plaintiff NBT Bank (NBT) for the face amount of the returned $706,000 check pursuant to 13 Pa. Cons.Stat. Ann. § 4302, even though NBT concedes that it suffered no injury as a result of the encoding error. Also at issue is whether NBT has standing to…