Buckingham Corp. v. Ewing Liquors Co.
Appellate Court of Illinois
323 N.E.2d 469 (Ill. App. Ct. 1975)
Buckingham Corporation (plaintiff) sued Ewing Liquors (defendant) for breach of contract, introducing a signed agreement bearing the signature of Buckingham vice president William Gallagan; Buckingham employee Herbik testified he hadn't witnessed the signing but recognized Gallagan's handwriting from routine business dealings, and also relayed (without objection) that Gallagan had later told him he'd signed it. The judge, sitting as trier of fact in a bench trial, ruled for Buckingham, and Ewing appealed, arguing the signature was never properly authenticated.
Whether lay witness testimony, based on familiarity with a person's handwriting from routine business dealings, is sufficient to authenticate that person's signature on a contract.