Samuel Rappaport Family Partnership v. Meridian Bank

Meridian Bank (defendant) issued a $100,000 letter of credit at McKlan's instruction, requiring, among other things, a certificate signed by Orleans -- the landlord who had been assigned the lease -- before payment. Orleans died before the draft was presented, so escrow agent Pincus presented the required draft along with a certificate signed instead by Rappaport (plaintiff), who had since bought the property from Orleans's estate. Meridian refused payment because the certificate wasn't signed by Orleans as the letter required, and Rappaport sued, arguing Orleans's death made the signature requirement ambiguous or obsolete; the trial court ruled for Meridian.