New Randolph Halsted Currency Exchange, Inc. v. Regent Title Insurance Agency, LLC 

Currency exchange qualified as a "holder in due course" in cashing check, later found to have been fraudulent, drawn on title insurance company's bank account. Even though check-cashing transaction raised some warning signals (incorrect spelling of payee's name, and two different purposes described for payment), currency exchange took commercially reasonable precautions by directly calling title insurance company and its bank to verify check. Court acted within its discretion to grant only one of currency exchange's motions for sanctions, where title insurance company had denied that it had drawn check on its bank account, but at trial its employee admitted having done so. (QUINN and MURPHY, concurring.)