## Facts

- Joan L. Parr maintained a checking account at Security National Bank.
- Parr wrote check no. 949 to Champlin Oil for $972.96 and mailed it on September 14, 1981.
- On September 15, 1981, Parr telephoned the Bank and ordered payment stopped, giving her account number, check number, date, payee, and an amount that was off by $0.50.
- On September 16 or 17, Parr executed a written stop-payment order dated September 15, 1981, repeating the same $0.50 error in the amount.
- The Bank paid check no. 949 on September 17, 1981, despite the stop-payment orders.
- Parr sued for the amount of the check, interest, attorney’s fees, and costs.
- The Bank asserted its computer system would stop payment only if the reported amount exactly matched the check amount; timeliness of notice was not disputed.

## Issues

1. Whether a stop-payment order gives a bank a “reasonable opportunity to act” under U.C.C. § 4-403(1) when the customer accurately identifies the check except for a $0.50 error in the amount.
2. Whether a bank may avoid liability by relying on internal computer programming that requires an exact match of the check amount.

## Decision

- The Oklahoma Court of Civil Appeals reversed the trial court’s judgment for the Bank.
- The court held Parr’s stop-payment order described the check with reasonable accuracy notwithstanding the $0.50 error.
- The court held the Bank had a reasonable opportunity to act on the order under U.C.C. § 4-403(1).
- The court rejected the Bank’s reliance on internal computer limitations as a defense.
- The case was remanded with directions to enter judgment for Parr for the amount of the check, attorney’s fees, and costs (with interest, if appropriate, to be calculated on remand).

## Legal Principles

- Under U.C.C. § 4-403(1), a stop-payment order is effective if received in time and in a manner that affords the bank a reasonable opportunity to act.
- “Reasonable opportunity” is assessed by an objective standard tied to whether the customer described the check with reasonable accuracy, not by the bank’s chosen internal processing methods.
- Minor discrepancies in a stop-payment description (including small errors in the amount) do not defeat the order when the check is otherwise readily identifiable by key descriptors (such as account number, check number, date, and payee).
- Losses from failure to stop payment, when the customer has provided a reasonably accurate description, fall on the bank as a cost of providing expected banking services.
- A bank’s uncommunicated operational requirement (such as an exact-amount match) does not shift the statutory risk to the customer.

## Conclusion

A customer’s stop-payment order that identifies a check with reasonable accuracy remains effective despite a minor amount error, and a bank that pays the check anyway is liable under U.C.C. § 4-403(1) regardless of internal computer processing rules requiring exact matches.


Parr v. Security Nat'l Bank, 680 P.2d 648 (Okla. Civ. App. 1984)