In re Estate of Rider

Rider, terminally ill, authorized Wachovia on June 17, 2005 to transfer $2 million from his account to his wife Carolyn's (defendant) new account, and the bank executed that transfer in installments on June 21, July 8 (the day Rider died and Wachovia learned of his death), July 11, and October 20; the personal representative of Rider's estate (plaintiff) sought a declaration that the post-death transfers belonged to the estate, with Carolyn arguing the UCC governed and Rider's daughters (the McClures) arguing agency law barred an agent from acting for a principal after learning of the principal's death. The probate court applied the UCC and found only the fourth transfer invalid; the court of appeals reversed to invalidate the third and fourth transfers as well, and the Supreme Court granted certiorari.