In re JD Services, Inc.

Bank of America (BofA) (plaintiff) mistakenly credited debtor JD Services' account with $725,000 instead of the $7,250 actually deposited; JD transferred the funds to a First Security Bank account before BofA caught the error, and by the time a hold was later placed on the excess $717,750, millions of dollars had already passed through the account in JD's ordinary course of business. The parties stipulated to the account activity, which yielded two different lowest-intermediate-balance figures depending on methodology: $717,750 under a simple Collected Balance approach counting total funds on deposit, versus $394,460.47 under an Available Balance approach accounting for holds reflecting what was actually available to withdraw. BofA sought return of the mistakenly credited funds via a constructive trust and moved for summary judgment.