Banque Worms v. BankAmerica International, and Third-Party Security Pacific International Bank, Third-Party

Summary

The New York Court of Appeals answered a certified question from the Second Circuit, holding that New York applies the "discharge for value" rule of Restatement §14 to mistaken electronic wire transfers. Accordingly, Banque Worms may retain the funds it received without showing detrimental reliance. The Court’s reasoning relied on longstanding New York restitution law, policy considerations of finality, and the Uniform Commercial Code Article 4A.