PSI Resources, LLC v. MB Financial Bank

Illinois Appellate Court
Civil Court
Uniform Commercial Code
Citation
Case Number: 
2016 IL App (1st) 152204
Decision Date: 
Friday, May 27, 2016
District: 
1st Dist.
Division/County: 
Cook Co., 5th Div.
Holding: 
Affirmed.
Justice: 
GORDON

Plaintiff filed breach of contract action against Defendant bank. Court properly dismissed suit as time-barred under 3-year statute of limitations in Section 4-111 of UCC. Ten-year period of statute of limitation for written contracts does not apply as it would not further purposes of UCC or promote commercial finality and certainty. Three-year limitations period applies as claim involved banking transactions involving negotiable instruments, anĀ  area of law specifically regulated by UCC.Discovery rule does not apply, as monthly account statements provided by Defendant provided sufficient information for Plaintiff to be put on notice that wrongful conduct had occurred.(REYES and LAMPKIN, concurring.)