Triffin v. Bridge View Bank

In Triffin v. Bridge View Bank, 330 N.J. Super. 473, 750 A.2d 136 (App.Div.2000), the Court held that plaintiff had no standing to sue the bank for failure to comply with N.J.S.A. 12A:4-302, the midnight deadline rule. This rule imposes accountability on a payor bank for the amount of an item presented to and received by the payor bank, if the bank "retains the item beyond midnight of the banking day of receipt without settling for it or, . . . does not pay or return the item or send notice of dishonor until after its midnight deadline." N.J.S.A. 12A:4-302(a)(1). The Court held that standing was limited to those entities who received the check prior to its dishonor because the statute confers standing to sue on a limited class, "'comprised of those involved in the collection and payment of the check at issue who may be directly harmed . . . by the failure of the payor bank to adhere to the . . . midnight deadline.'" Bridge View Bank, supra, 330 N.J. Super. at 477, 750 A.2d 136.