Triffin v. Dillabough
Supreme Court of Pennsylvania
716 A.2d 605 (1998)
Relevant factsFree
Dillabough and Lynn (defendants) presented stolen, blank American Express money orders for payment at Chuckie's, which paid them and then assigned its rights to Triffin (plaintiff) after American Express (defendant) refused reimbursement, arguing the money orders' back-of-form conditions addressing theft, alteration, and forgery made them non-negotiable; the trial court agreed and ruled for American Express, but the superior court reversed, finding the orders negotiable and Triffin a holder in due course.
IssueFree
Whether a writing that is otherwise a negotiable instrument is made non-negotiable by including an implied condition or a condition that merely reflects the law.