First National Bank of Chicago v. Standard Bank & Trust
United States Court of Appeals for the Seventh Circuit
172 F.3d 472 (1999)
On the same day, First National Bank of Chicago (plaintiff) and Standard Bank & Trust (defendant) each deposited roughly $4 million in checks drawn on the other's accounts; both presented the checks to each other the next day. Three days later, First National returned all the Standard Bank checks it had received. The next afternoon, once Standard Bank learned of First National's return, it personally sent three bank officers to First National's processing center to hand-deliver the checks Standard Bank was returning. First National refused to credit Standard Bank, arguing the return was untimely, and sued for a declaratory judgment; Standard Bank counterclaimed for prejudgment interest, and the district court ruled for Standard Bank on both.
Whether a payor bank's midnight deadline to pay or return a check is extended when the bank uses a means of delivery that would ordinarily result in the check reaching the receiving bank by the next business day after the deadline.