Maurice O’Meara Company, Appellant v. the National Park Bank of New York, Respondent

Summary

The New York Court of Appeals reversed the Appellate Division and granted the plaintiff’s motion for summary judgment, holding that a bank’s obligation under an irrevocable letter of credit is triggered solely by the presentation of documents that satisfy the credit’s terms, regardless of any alleged defects in the underlying goods. The court rejected the bank’s defenses that it could require testing of tensile strength or that an oral modification altered the credit. A dissent argued that the bank should be allowed to refuse payment when the documents misrepresent the merchandise.