Valley Bank of Ronan v. Hughes

In Valley Bank of Ronan v. Hughes, 2006 MT 285, 334 Mont. 335, 147 P.3d 185 (Sup. Ct. Mont. 2006), the customer alleged that the bank had made misrepresentations about the check settlement process. He then sued the bank claiming that it had inappropriately charged back his account after the dishonor of the deposited checks. The Montana Supreme Court reasoned that because such communications are not addressed with specificity by the UCC, common law and equitable principles supplement the UCC and govern the legal rights and responsibilities that applied to the bank's representations to the customer, upon which the customer allegedly relied. Id. The Montana Supreme Court thus held that common law principles apply to bank communications to a depositor inquiring about the processing of checks. Id. at 192.