Ads Associates Group, Inc., and Brendan Allen, Plaintiffs-Respondents v. Oritani Savings Bank, Defendant-Appellant…

Summary

The Supreme Court of New Jersey reversed the Appellate Division and reinstated the trial court’s dismissal of Brendan Allen’s common‑law negligence claim against Oritani Savings Bank, holding that Allen, not being a customer under UCC Article 4A, cannot assert a non‑customer negligence claim and that Article 4A precludes such a claim. The Court also rejected the existence of a special relationship under City Check Cashing. Justice Albin’s dissent argued that Allen should be allowed to sue on negligence and misrepresentation grounds.