Wood v. State Bank

As part of a real-estate transaction, State Bank (defendant) issued a standby letter of credit payable to attorney Wood (plaintiff) if Jacklyn Construction defaulted, conditioned on presenting a draft referencing the correct credit number along with Wood's certification that Jacklyn had willfully failed to close title. Wood presented a draft without the credit number, accompanied by an affidavit that referenced the number but omitted any certification of willful default. State Bank refused payment, and the sellers sued; both sides moved for summary judgment, and the trial court sided with the sellers.

Whether, under state commercial law, a bank must make payment on a standby letter of credit if the presentment does not strictly comply with the letter of credit's requirements.