Woodworth v. Richmond Indiana Venture

Woodworth (plaintiff) signed a promissory note as partial payment for a partnership investment; the note provided that if payments were late, the partnership (not the note's holder) could, at its option, declare that Woodworth forfeited his partnership interest. The note was later assigned to Signet Bank (defendant). After Woodworth defaulted and Signet sued, Woodworth argued Signet was not a holder in due course because the note wasn't negotiable, limiting the defenses Signet could cut off; both sides moved for summary judgment.

Whether a negotiable instrument may contain any promise or order from the maker other than an unconditional promise to pay a sum certain.