New York Court of Appeals

Lawrence Laudisi, Respondent v. American Exchange National Bank, Appellant

December 19, 1924239 N.Y. 234

Summary

The Court held that a bill of lading with a generic description, when supplemented by a proper invoice, satisfies the document requirements of a letter of credit, obligating the bank to pay the draft; consequently the defendant's motion to dismiss the plaintiff's complaint was granted and the plaintiff's summary judgment was denied. Justice Crane dissented, arguing that the documents did not meet the letter of credit's requirements and that the dismissal should not be granted.