Mark D. Dean, P.s.c. v. Commonwealth Bank & Trust Company

Summary

The Court affirmed summary judgment for Commonwealth Bank, holding that the firm's claims were barred by the three-year statute of limitations. The Court held that the employee's checks did not bear unauthorized signatures under the UCC because she had apparent authority as an authorized signatory, and therefore the one-year repose period did not apply. It further held that the firm's common-law claims were displaced by the UCC's comprehensive scheme governing check transactions and were likewise untimely.