ADS Associates Group, Inc. v. Oritani Savings Bank
(A-114-11; 069987)
Allen may not assert a UCC Article 4A claim against Oritani because he is not a bank “customer” under the statute. Allen also may not assert a common law negligence claim against Oritani because such a claim would contravene the objectives of Article 4A. Even if Article 4A did not bar Allen’s negligence claim, no “special relationship” existed to create a duty of care between Oritani and Allen under City Check Cashing, 166 N.J. 49.
