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The 2023 Florida Statutes (including Special Session C)

Title XXXIX
COMMERCIAL RELATIONS
Chapter 675
UNIFORM COMMERCIAL CODE: LETTERS OF CREDIT
View Entire Chapter
CHAPTER 675
CHAPTER 675
UNIFORM COMMERCIAL CODE: LETTERS OF CREDIT

ARTICLE 5

675.101 Short title.
675.102 Scope.
675.103 Definitions.
675.104 Formal requirements.
675.105 Consideration.
675.106 Issuance, amendment, cancellation, and duration.
675.107 Confirmer, nominated person, and adviser.
675.108 Issuer’s rights and obligations.
675.109 Fraud and forgery.
675.110 Warranties.
675.111 Remedies.
675.112 Transfer of letter of credit.
675.113 Transfer by operation of law.
675.114 Assignment of proceeds.
675.115 Statute of limitations.
675.116 Choice of law and forum.
675.117 Subrogation of issuer, applicant, and nominated person.
675.118 Applicability of ch. 99-137.
675.1181 Security interest of issuer or nominated person.
675.101 Short title.This chapter may be cited as the “Uniform Commercial Code—Letters of Credit.”
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-101, U.C.C.
675.102 Scope.
(1) This chapter applies to letters of credit and to certain rights and obligations arising out of transactions involving letters of credit.
(2) The statement of a rule in this chapter does not by itself require, imply, or negate application of the same or a different rule to a situation not provided for, or to a person not specified, in this chapter.
(3) With the exception of this subsection, subsections (1) and (4), ss. 675.103(1)(i) and (j), 675.106(4), and 675.114(4), and except to the extent prohibited in ss. 671.102(2) and 675.117(4), the effect of this chapter may be varied by agreement or by a provision stated or incorporated by reference in an undertaking. A term in an agreement or undertaking generally excusing liability or generally limiting remedies for failure to perform obligations is not sufficient to vary obligations prescribed by this chapter.
(4) Rights and obligations of an issuer to a beneficiary or a nominated person under a letter of credit are independent of the existence, performance, or nonperformance of a contract or arrangement out of which the letter of credit arises or which underlies it, including contracts or arrangements between the issuer and the applicant and between the applicant and the beneficiary.
History.s. 1, ch. 65-254; s. 1, ch. 99-137; s. 25, ch. 2007-134.
Note.s. 5-102, U.C.C.
675.103 Definitions.
(1) For purposes of this chapter:
(a) “Adviser” means a person who, at the request of the issuer, a confirmer, or another adviser, notifies or requests another adviser to notify the beneficiary that a letter of credit has been issued, confirmed, or amended.
(b) “Applicant” means a person at whose request or for whose account a letter of credit is issued. The term includes a person who requests an issuer to issue a letter of credit on behalf of another if the person making the request undertakes an obligation to reimburse the issuer.
(c) “Beneficiary” means a person who under the terms of a letter of credit is entitled to have its complying presentation honored. The term includes a person to whom drawing rights have been transferred under a transferable letter of credit.
(d) “Confirmer” means a nominated person who undertakes, at the request or with the consent of the issuer, to honor a presentation under a letter of credit issued by another.
(e) “Dishonor” of a letter of credit means failure timely to honor or to take an interim action, such as acceptance of a draft, that may be required by the letter of credit.
(f) “Document” means a draft or other demand, document of title, investment security, certificate, invoice, or other record, statement, or representation of fact, law, right, or opinion which is presented in a written or other medium permitted by the letter of credit or, unless prohibited by the letter of credit, by the standard practice referred to in s. 675.108(5) and which is capable of being examined for compliance with the terms and conditions of the letter of credit. A document may not be oral.
(g) “Good faith” means honesty in fact in the conduct or transaction concerned.
(h) “Honor” of a letter of credit means performance of the issuer’s undertaking in the letter of credit to pay or deliver an item of value. Unless the letter of credit otherwise provides, “honor” occurs:
1. Upon payment;
2. If the letter of credit provides for acceptance, upon acceptance of a draft and paying the draft at maturity; or
3. If the letter of credit provides for incurring a deferred obligation, upon incurring the obligation and performing the obligation at maturity.
(i) “Issuer” means a bank or other person that issues a letter of credit, but does not include an individual who makes an engagement for personal, family, or household purposes.
(j) “Letter of credit” means a definite undertaking that satisfies the requirements of s. 675.104 by an issuer to a beneficiary at the request or for the account of an applicant or, in the case of a financial institution, to itself or for its own account, to honor a documentary presentation by payment or delivery of an item of value.
(k) “Nominated person” means a person whom the issuer designates or authorizes to pay, accept, negotiate, or otherwise give value under a letter of credit and undertakes by agreement or custom and practice to reimburse.
(l) “Presentation” means delivery of a document to an issuer or nominated person for honor or giving of value under a letter of credit.
(m) “Presenter” means a person making a presentation as or on behalf of a beneficiary or nominated person.
(n) “Record” means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form.
(o) “Successor of a beneficiary” means a person who succeeds to substantially all of the rights of a beneficiary by operation of law, including a corporation with or into which the beneficiary has been merged or consolidated, an administrator, executor, personal representative, trustee in bankruptcy, debtor in possession, liquidator, and receiver.
(2) The following definitions and the sections in which they appear in other chapters apply to this chapter:

“Acceptance,” s. 673.4091.

“Value,” ss. 673.3031 and 674.2111.

(3) The provisions of part II of chapter 671 apply to this chapter.
History.s. 1, ch. 65-254; s. 49, ch. 92-82; s. 1, ch. 99-137.
Note.s. 5-103, U.C.C.; supersedes s. 676.06.
675.104 Formal requirements.A letter of credit, confirmation, advice, transfer, amendment, or cancellation may be issued in any form that is a record and is authenticated by a signature or in accordance with the agreement of the parties or the standard practice referred to in s. 675.108(5).
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-104, U.C.C.
675.105 Consideration.Consideration is not required to issue, amend, transfer, or cancel a letter of credit, advice, or confirmation.
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-105, U.C.C.; supersedes ss. 674.27, 674.31.
675.106 Issuance, amendment, cancellation, and duration.
(1) A letter of credit is issued and becomes enforceable according to its terms against the issuer when the issuer sends or otherwise transmits it to the person requested to advise or to the beneficiary. A letter of credit is revocable only if it so provides.
(2) After a letter of credit is issued, rights and obligations of a beneficiary, applicant, confirmer, and issuer are not affected by an amendment or cancellation to which that person has not consented except to the extent the letter of credit provides that it is revocable or that the issuer may amend or cancel the letter of credit without that consent.
(3) If there is no stated expiration date or other provision that determines its duration, a letter of credit expires 1 year after its stated date of issuance or, if none is stated, after the date on which it is issued.
(4) A letter of credit that states that it is perpetual expires 5 years after its stated date of issuance or, if none is stated, after the date on which it is issued.
History.s. 1, ch. 65-254; s. 615, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-106, U.C.C.
675.107 Confirmer, nominated person, and adviser.
(1) A confirmer is directly obligated on a letter of credit and has the rights and obligations of an issuer to the extent of its confirmation. The confirmer also has rights against and obligations to the issuer as if the issuer were an applicant and the confirmer had issued the letter of credit at the request and for the account of the issuer.
(2) A nominated person who is not a confirmer is not obligated to honor or otherwise give value for a presentation.
(3) A person requested to advise may decline to act as an adviser. An adviser that is not a confirmer is not obligated to honor or give value for a presentation. An adviser undertakes to the issuer and to the beneficiary accurately to advise the terms of the letter of credit, confirmation, amendment, or advice received by that person and undertakes to the beneficiary to check the apparent authenticity of the request to advise. Even if the advice is inaccurate, the letter of credit, confirmation, or amendment is enforceable as issued.
(4) A person who notifies a transferee beneficiary of the terms of a letter of credit, confirmation, amendment, or advice has the rights and obligations of an adviser under subsection (3). The terms in the notice to the transferee beneficiary may differ from the terms in any notice to the transferor beneficiary to the extent permitted by the letter of credit, confirmation, amendment, or advice received by the person who so notifies.
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-107, U.C.C.
675.108 Issuer’s rights and obligations.
(1) Except as otherwise provided in s. 675.109, an issuer shall honor a presentation that, as determined by the standard practice referred to in subsection (5), appears on its face strictly to comply with the terms and conditions of the letter of credit. Except as otherwise provided in s. 675.113 and unless otherwise agreed with the applicant, an issuer shall dishonor a presentation that does not appear so to comply.
(2) An issuer has a reasonable time after presentation, but not beyond the end of the seventh business day of the issuer after the day of its receipt of documents:
(a) To honor;
(b) If the letter of credit provides for honor to be completed more than 7 business days after presentation, to accept a draft or incur a deferred obligation; or
(c) To give notice to the presenter of discrepancies in the presentation.
(3) Except as otherwise provided in subsection (4), an issuer is precluded from asserting as a basis for dishonor any discrepancy if timely notice is not given, or any discrepancy not stated in the notice if timely notice is given.
(4) Failure to give the notice specified in subsection (2) or to mention fraud, forgery, or expiration in the notice does not preclude the issuer from asserting as a basis for dishonor fraud or forgery as described in s. 675.109(1) or expiration of the letter of credit before presentation.
(5) An issuer shall observe standard practice of financial institutions that regularly issue letters of credit. Determination of the issuer’s observance of the standard practice is a matter of interpretation for the court. The court shall offer the parties a reasonable opportunity to present evidence of the standard practice.
(6) An issuer is not responsible for:
(a) The performance or nonperformance of the underlying contract, arrangement, or transaction;
(b) An act or omission of others; or
(c) Observance or knowledge of the usage of a particular trade other than the standard practice referred to in subsection (5).
(7) If an undertaking constituting a letter of credit under s. 675.103(1)(j) contains nondocumentary conditions, an issuer shall disregard the nondocumentary conditions and treat such conditions as if unstated.
(8) An issuer that has dishonored a presentation shall return the documents or hold them at the disposal of, and send advice to that effect to, the presenter.
(9) An issuer that has honored a presentation as permitted or required by this chapter:
(a) Is entitled to be reimbursed by the applicant in immediately available funds not later than the date of its payment of funds.
(b) Takes the documents free of claims of the beneficiary or presenter.
(c) Is precluded from asserting a right of recourse on a draft under ss. 673.4141 and 673.4151.
(d) Except as otherwise provided in ss. 675.110 and 675.117, is precluded from restitution of money paid or other value given by mistake to the extent the mistake concerns discrepancies in the documents or tender which are apparent on the face of the presentation.
(e) Is discharged to the extent of its performance under the letter of credit unless the issuer honored a presentation in which a required signature of a beneficiary was forged.
History.s. 1, ch. 65-254; s. 616, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-108, U.C.C.
675.109 Fraud and forgery.
(1) If a presentation is made that appears on its face strictly to comply with the terms and conditions of the letter of credit, but a required document is forged or materially fraudulent, or honor of the presentation would facilitate a material fraud by the beneficiary on the issuer or applicant:
(a) The issuer shall honor the presentation, if honor is demanded by:
1. A nominated person who has given value in good faith and without notice of forgery or material fraud;
2. A confirmer who has honored its confirmation in good faith;
3. A holder in due course of a draft drawn under the letter of credit which was taken after acceptance by the issuer or nominated person; or
4. An assignee of the issuer’s or nominated person’s deferred obligation that was taken for value and without notice of forgery or material fraud after the obligation was incurred by the issuer or nominated person.
(b) The issuer, acting in good faith, may honor or dishonor the presentation in any other case.
(2) If an applicant claims that a required document is forged or materially fraudulent or that honor of the presentation would facilitate a material fraud by the beneficiary on the issuer or applicant, a court of competent jurisdiction may temporarily or permanently enjoin the issuer from honoring a presentation or grant similar relief against the issuer or other persons only if the court finds that:
(a) The relief is not prohibited under the law applicable to an accepted draft or deferred obligation incurred by the issuer;
(b) A beneficiary, issuer, or nominated person who may be adversely affected is adequately protected against loss that it may suffer because the relief is granted;
(c) All of the conditions to entitle a person to the relief under the laws of this state have been met; and
(d) On the basis of the information submitted to the court, the applicant is more likely than not to succeed under its claim of forgery or material fraud and the person demanding honor does not qualify for protection under paragraph (1)(a).
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-109, U.C.C.
675.110 Warranties.
(1) If a beneficiary’s presentation is honored, the beneficiary warrants:
(a) To the issuer, any other person to whom presentation is made, and the applicant that there is no fraud or forgery of the kind described in s. 675.109(1); and
(b) To the applicant that the drawing does not violate any agreement between the applicant and beneficiary or any other agreement intended by them to be augmented by the letter of credit.
(2) The warranties in subsection (1) are in addition to warranties arising under chapters 673, 674, 677, and 678 because of the presentation or transfer of documents covered by any of those chapters.
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-110, U.C.C.
675.111 Remedies.
(1) If an issuer wrongfully dishonors or repudiates its obligation to pay money under a letter of credit before presentation, the beneficiary, successor, or nominated person presenting on its own behalf may recover from the issuer the amount that is the subject of the dishonor or repudiation. If the issuer’s obligation under the letter of credit is not for the payment of money, the claimant may obtain specific performance or, at the claimant’s election, recover an amount equal to the value of performance from the issuer. In either case, the claimant may also recover incidental but not consequential damages. The claimant is not obligated to take action to avoid damages that might be due from the issuer under this subsection. If, although not obligated to do so, the claimant avoids damages, the claimant’s recovery from the issuer must be reduced by the amount of damages avoided. The issuer has the burden of proving the amount of damages avoided. In the case of repudiation the claimant need not present any document.
(2) If an issuer wrongfully dishonors a draft or demand presented under a letter of credit or honors a draft or demand in breach of its obligation to the applicant, the applicant may recover damages resulting from the breach, including incidental but not consequential damages, less any amount saved as a result of the breach.
(3) If an adviser or nominated person other than a confirmer breaches an obligation under this chapter or an issuer breaches an obligation not covered in subsection (1) or subsection (2), a person to whom the obligation is owed may recover damages resulting from the breach, including incidental but not consequential damages, less any amount saved as a result of the breach. To the extent of the confirmation, a confirmer has the liability of an issuer specified in this subsection and subsections (1) and (2).
(4) An issuer, nominated person, or adviser who is found liable under subsection (1), subsection (2), or subsection (3) shall pay interest on the amount owed thereunder from the date of wrongful dishonor or other appropriate date.
(5) Reasonable attorney’s fees and other expenses of litigation must be awarded to the prevailing party in an action in which a remedy is sought under this chapter.
(6) Damages that would otherwise be payable by a party for breach of an obligation under this chapter may be liquidated by agreement or undertaking, but only in an amount or by a formula that is reasonable in light of the harm anticipated.
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-111, U.C.C.; supersedes s. 675.32.
675.112 Transfer of letter of credit.
(1) Except as otherwise provided in s. 675.113, unless a letter of credit provides that it is transferable, the right of a beneficiary to draw or otherwise demand performance under a letter of credit may not be transferred.
(2) Even if a letter of credit provides that it is transferable, the issuer may refuse to recognize or carry out a transfer if:
(a) The transfer would violate applicable law; or
(b) The transferor or transferee has failed to comply with any requirement stated in the letter of credit or any other requirement relating to transfer imposed by the issuer which is within the standard practice referred to in s. 675.108(5) or is otherwise reasonable under the circumstances.
History.s. 1, ch. 65-254; s. 617, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-112, U.C.C.; supersedes s. 676.07.
675.113 Transfer by operation of law.
(1) A successor of a beneficiary may consent to amendments, sign and present documents, and receive payment or other items of value in the name of the beneficiary without disclosing its status as a successor.
(2) A successor of a beneficiary may consent to amendments, sign and present documents, and receive payment or other items of value in its own name as the disclosed successor of the beneficiary. Except as otherwise provided in subsection (5), an issuer shall recognize a disclosed successor of a beneficiary as beneficiary in full substitution for its predecessor upon compliance with the requirements for recognition by the issuer of a transfer of drawing rights by operation of law under the standard practice referred to in s. 675.108(5) or, in the absence of such a practice, compliance with other reasonable procedures sufficient to protect the issuer.
(3) An issuer is not obliged to determine whether a purported successor is a successor of a beneficiary or whether the signature of a purported successor is genuine or authorized.
(4) Honor of a purported successor’s apparently complying presentation under subsection (1) or subsection (2) has the consequences specified in s. 675.108(9) even if the purported successor is not the successor of a beneficiary. Documents signed in the name of the beneficiary or of a disclosed successor by a person who is neither the beneficiary nor the successor of the beneficiary are forged documents for the purposes of s. 675.109.
(5) An issuer whose rights of reimbursement are not covered by subsection (4) or substantially similar law and any confirmer or nominated person may decline to recognize a presentation under subsection (2).
(6) A beneficiary whose name is changed after the issuance of a letter of credit has the same rights and obligations as a successor of a beneficiary under this section.
History.s. 1, ch. 65-254; s. 618, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-113, U.C.C.
675.114 Assignment of proceeds.
(1) For purposes of this section, the term “proceeds of a letter of credit” means the cash, check, accepted draft, or other item of value paid or delivered upon honor or giving of value by the issuer or any nominated person under the letter of credit. The term does not include a beneficiary’s drawing rights or documents presented by the beneficiary.
(2) A beneficiary may assign its right to part or all of the proceeds of a letter of credit. The beneficiary may do so before presentation as a present assignment of its right to receive proceeds contingent upon its compliance with the terms and conditions of the letter of credit.
(3) An issuer or nominated person need not recognize an assignment of proceeds of a letter of credit until it consents to the assignment.
(4) An issuer or nominated person has no obligation to give or withhold its consent to an assignment of proceeds of a letter of credit, but consent may not be unreasonably withheld if the assignee possesses and exhibits the letter of credit and presentation of the letter of credit is a condition to honor.
(5) Rights of a transferee beneficiary or nominated person are independent of the beneficiary’s assignment of the proceeds of a letter of credit and are superior to the assignee’s right to the proceeds.
(6) Neither the rights recognized by this section between an assignee and an issuer, transferee beneficiary, or nominated person nor the issuer’s or nominated person’s payment of proceeds to an assignee or a third person affect the rights between the assignee and any person other than the issuer, transferee beneficiary, or nominated person. The mode of creating and perfecting a security interest in or granting an assignment of a beneficiary’s rights to proceeds is governed by chapter 679 or other law. Against persons other than the issuer, transferee beneficiary, or nominated person, the rights and obligations arising upon the creation of a security interest or other assignment of a beneficiary’s right to proceeds and its perfection are governed by chapter 679 or other law.
History.s. 1, ch. 65-254; s. 3, ch. 87-275; s. 50, ch. 92-82; s. 23, ch. 98-11; s. 1, ch. 99-137.
Note.s. 5-114, U.C.C.
675.115 Statute of limitations.An action to enforce a right or obligation arising under this chapter must be commenced within 1 year after the expiration date of the relevant letter of credit or 1 year after the cause of action accrues, whichever occurs later. A cause of action accrues when the breach occurs, regardless of the aggrieved party’s lack of knowledge of the breach.
History.s. 1, ch. 65-254; s. 619, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-115, U.C.C.
675.116 Choice of law and forum.
(1) The liability of an issuer, nominated person, or adviser for action or omission is governed by the law of the jurisdiction chosen by an agreement in the form of a record signed or otherwise authenticated by the affected parties in the manner provided in s. 675.104 or by a provision in the person’s letter of credit, confirmation, or other undertaking. The jurisdiction whose law is chosen need not bear any relation to the transaction.
(2) Unless subsection (1) applies, the liability of an issuer, nominated person, or adviser for action or omission is governed by the law of the jurisdiction in which the person is located. The person is considered to be located at the address indicated in the person’s undertaking. If more than one address is indicated, the person is considered to be located at the address from which the person’s undertaking was issued. For the purpose of jurisdiction, choice of law, and recognition of interbranch letters of credit, but not enforcement of a judgment, all branches of a bank are considered separate juridical entities and a bank is considered to be located at the place where its relevant branch is considered to be located under this subsection.
(3) Except as otherwise provided in this subsection, the liability of an issuer, nominated person, or adviser is governed by any rules of custom or practice, such as the Uniform Customs and Practice for Documentary Credits, to which the letter of credit, confirmation, or other undertaking is expressly made subject. If this chapter governs the liability of an issuer, nominated person, or adviser under subsection (1) or subsection (2), the relevant undertaking incorporates rules of custom or practice, and there is conflict between this chapter and such rules as applied to that undertaking, such rules govern except to the extent of any conflict with the nonvariable provisions specified in s. 675.102(3).
(4) This chapter governs to the extent of any conflict between this chapter and chapter 670, chapter 673, chapter 674, or chapter 679.
(5) The forum for settling disputes arising out of an undertaking within this chapter may be chosen in the manner and with the binding effect that governing law may be chosen in accordance with subsection (1).
History.s. 1, ch. 65-254; s. 5, ch. 79-398; s. 620, ch. 97-102; s. 1, ch. 99-137.
Note.s. 5-116, U.C.C.
675.117 Subrogation of issuer, applicant, and nominated person.
(1) An issuer that honors a beneficiary’s presentation is subrogated to the rights of the beneficiary to the same extent as if the issuer were a secondary obligor of the underlying obligation owed to the beneficiary and of the applicant to the same extent as if the issuer were the secondary obligor of the underlying obligation owed to the applicant.
(2) An applicant that reimburses an issuer is subrogated to the rights of the issuer against any beneficiary, presenter, or nominated person to the same extent as if the applicant were the secondary obligor of the obligations owed to the issuer and has the rights of subrogation of the issuer to the rights of the beneficiary stated in subsection (1).
(3) A nominated person who pays or gives value against a draft or demand presented under a letter of credit is subrogated to the rights of:
(a) The issuer against the applicant to the same extent as if the nominated person were a secondary obligor of the obligation owed to the issuer by the applicant;
(b) The beneficiary to the same extent as if the nominated person were a secondary obligor of the underlying obligation owed to the beneficiary; and
(c) The applicant to the same extent as if the nominated person were a secondary obligor of the underlying obligation owed to the applicant.
(4) Notwithstanding any agreement or term to the contrary, the rights of subrogation stated in subsections (1) and (2) do not arise until the issuer honors the letter of credit or otherwise pays and the rights in subsection (3) do not arise until the nominated person pays or otherwise gives value. Until then, the issuer, nominated person, and the applicant do not derive under this section present or prospective rights forming the basis of a claim, defense, or excuse.
History.s. 1, ch. 65-254; s. 1, ch. 99-137.
Note.s. 5-117, U.C.C.
675.118 Applicability of ch. 99-137.
(1) This act applies to any letter of credit that is issued on or after July 1, 1999. This act does not apply to any transaction, event, obligation, or duty arising out of or associated with a letter of credit issued before July 1, 1999, including any amendment to the letter of credit that was made after such date, unless the amendment provides otherwise.
(2) A transaction arising out of or associated with a letter of credit issued before July 1, 1999, and the rights, obligations, and interests created by that transaction are governed by any law amended or repealed by this act to the same extent as if such amendment or repeal had not occurred and such transaction may be terminated, completed, consummated, or enforced under such law prior to its amendment or repeal.
History.ss. 10, 11, ch. 99-137.
675.1181 Security interest of issuer or nominated person.
(1) An issuer or nominated person has a security interest in a document presented under a letter of credit to the extent that the issuer or nominated person honors or gives value for the presentation.
(2) As long as and to the extent that an issuer or nominated person has not been reimbursed or has not otherwise recovered the value given with respect to a security interest in a document under subsection (1), the security interest continues and is subject to chapter 679, but a security agreement is not necessary to make the security interest enforceable under s. 679.2031(2)(c):
(a) If the document is presented in a medium other than a written or other tangible medium, the security interest is perfected; and
(b) If the document is presented in a written or other tangible medium and is not a certificated security, chattel paper, a document of title, an instrument, or a letter of credit, the security interest is perfected and has priority over a conflicting security interest in the document so long as the debtor does not have possession of the document.
History.s. 17, ch. 2001-198.

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Annotations, Discussions, Cases:

Cases from cite.case.law:

J. TRUMP, v. MAZARS USA, LLP, J. v. AG,, 140 S. Ct. 2019 (U.S. 2020)

. . . few" documents that might not relate to the committees' legislative purposes. 943 F.3d 627, 667-668, 675 . . .

LITTLE SISTERS OF THE POOR SAINTS PETER AND PAUL HOME, v. PENNSYLVANIA, J. v., 140 S. Ct. 2367 (U.S. 2020)

. . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 696-697, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014). . . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014), we held that RFRA prohibited . . . Population Services Int'l , 431 U.S. 678, 97 S.Ct. 2010, 52 L.Ed.2d 675 (1977). . . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 717, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014) (noting the oddity . . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 699, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014). . . .

JUNE MEDICAL SERVICES L. L. C. v. RUSSO, v. LLC., 140 S. Ct. 2103 (U.S. 2020)

. . . Population Services Int'l , 431 U.S. 678, 97 S.Ct. 2010, 52 L.Ed.2d 675 (1977) (distributors of contraceptives . . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 694-695, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014) (asking whether . . .

J. THOLE, v. U. S. BANK N. A, 140 S. Ct. 1615 (U.S. 2020)

. . . Hobby Lobby Stores, Inc. , 573 U.S. 682, 715, and n. 26, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014). . . .

GE ENERGY POWER CONVERSION FRANCE SAS, CORP. SAS, v. OUTOKUMPU STAINLESS USA, LLC,, 140 S. Ct. 1637 (U.S. 2020)

. . . Co. , 675 F.3d 355, 375 (CA4 2012), and Sourcing Unlimited, Inc. v. . . .

FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO, v. AURELIUS INVESTMENT, LLC, LLC, III v. LLC, v. LLC, n De De La El Y v., 140 S. Ct. 1649 (U.S. 2020)

. . . three-judge court panel to consider any action seeking to enjoin a " 'State statute.' " 416 U.S. at 675 . . .

UNITED STATES, v. SINENENG- SMITH, 140 S. Ct. 1575 (U.S. 2020)

. . . Y. , 385 U.S. 589, 87 S.Ct. 675, 17 L.Ed.2d 629 (1967). . . .

GEORGIA, v. PUBLIC. RESOURCE. ORG, INC., 140 S. Ct. 1498 (U.S. 2020)

. . . Valladolid , 565 U.S. 207, 216, 132 S.Ct. 680, 181 L.Ed.2d 675 (2012). . . .

NEW YORK STATE RIFLE PISTOL ASSOCIATION, INC. v. CITY OF NEW YORK, NEW YORK,, 140 S. Ct. 1525 (U.S. 2020)

. . . Miller , 675 F.2d 151, 158 (C.A.7 1982) ("It is well-settled that the district court may grant monetary . . .

COUNTY OF MAUI, HAWAII, v. HAWAII WILDLIFE FUND,, 140 S. Ct. 1462 (U.S. 2020)

. . . Army Corps of Engineers , 531 U.S. 159, 174, 121 S.Ct. 675, 148 L.Ed.2d 576 (2001) ( SWANCC ), and when . . .

THRYV, INC. v. CLICK- TO- CALL TECHNOLOGIES, LP,, 140 S. Ct. 1367 (U.S. 2020)

. . . Schor , 478 U.S. 833, 851, 106 S.Ct. 3245, 92 L.Ed.2d 675 (1986) ; see also Oil States , 584 U.S., at . . .

KANSAS, v. GLOVER, 140 S. Ct. 1183 (U.S. 2020)

. . . Sharpe , 470 U.S. 675, 682, 105 S.Ct. 1568, 84 L.Ed.2d 605 (1985) ). . . .

BANK OF AMERICA CORPORATION, v. CITY OF MIAMI, FLORIDA, 140 S. Ct. 1259 (U.S. 2020)

. . . CITY OF MIAMI, FLORIDA ; No. 19-675. Supreme Court of the United States. . . .

C. HERNANDEZ, v. MESA, Jr., 140 S. Ct. 735 (U.S. 2020)

. . . Iqbal , 556 U.S. 662, 675, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) ), and have gone so far as to observe . . .

ELHADY, v. H. KABLE,, 391 F. Supp. 3d 562 (E.D. Va. 2019)

. . . Lyons , 461 U.S. 95, 102, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983) ). . . .

REPRODUCTIVE HEALTH SERVICES OF PLANNED PARENTHOOD OF ST. LOUIS REGION, INC. P. D. O. M. S. C. I. F. A. C. O. G, v. L. PARSON,, 389 F. Supp. 3d 631 (W.D. Mo. 2019)

. . . Franklin, 439 U.S. 379, 388-89, 99 S.Ct. 675, 58 L.Ed.2d 596 (1979), that " 'neither the legislature . . .

B. VANZANT v. HILL S PET NUTRITION, INC., 934 F.3d 730 (7th Cir. 2019)

. . . Suzuki Motor Co. , 174 Ill.2d 482, 221 Ill.Dec. 389, 675 N.E.2d 584, 593 (1996). . . . that the plaintiffs' purchases "occurred after the allegedly fraudulent statements." 221 Ill.Dec. 389, 675 . . .

BACA v. COLORADO DEPARTMENT OF STATE, G. T. L. M., 935 F.3d 887 (10th Cir. 2019)

. . . Lyons , 461 U.S. 95, 109-10, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983) (recognizing a plaintiff's standing . . .

UNITED STATES v. CUEVAS- LOPEZ,, 934 F.3d 1056 (9th Cir. 2019)

. . . Franklin , 439 U.S. 379, 392-393 n.10, 99 S.Ct. 675, 58 L.Ed.2d 596 (1979) ). . . .

PASSARO, Jr. v. VIRGINIA, 935 F.3d 243 (4th Cir. 2019)

. . . Stewart , 563 U.S. 247, 253-54, 131 S.Ct. 1632, 179 L.Ed.2d 675 (2011) ; Puerto Rico Aqueduct & Sewer . . .

BOXILL, v. P. O GRADY E. E. T., 935 F.3d 510 (6th Cir. 2019)

. . . Jones-Kelley , 675 F.3d 580, 583 (6th Cir. 2012). . . . Wurzelbacher , 675 F.3d at 583. . . .

NEW YORK STATE CITIZENS COALITION FOR CHILDREN, v. J. POOLE,, 935 F.3d 56 (2nd Cir. 2019)

. . . . § 675(4)(A), pursuant to a statute that contains not a word of guidance for making such judgments. . . . See 42 U.S.C. §§ 671, 675. . . . This is not a reasonable interpretation of §§ 672 and 675. . . . Id . § 675(4)(A). . . . No. 110-351,122 Stat. 3949 (2008) (current version at 42 U.S.C. § 675(4)(A) ). . . .

HAWKINS v. I- TV DIGITALIS TAVKOZLESI ZRT. f k a DMCC Rt. DIGI RCS RDS S. A. RCS S. A. DIGI N. V. v. i- TV f k a DMCC Rt. DIGI RCS RDS S. A. RCS S. A. DIGI N. V., 935 F.3d 211 (4th Cir. 2019)

. . . Homa , 514 F.3d 661, 675 (7th Cir. 2008). . . .

ARCHER AND WHITE SALES, INCORPORATED, v. HENRY SCHEIN, INCORPORATED L. L. C. L. L. C., 935 F.3d 274 (5th Cir. 2019)

. . . DynMcDermott Petroleum Operations Co. , 687 F.3d 671, 675 (5th Cir. 2012). Am. . . .

IN RE NATIONAL FOOTBALL LEAGUE S SUNDAY TICKET ANTITRUST LITIGATION, Jr. v. LLC LLC NFL LLC LLC LP LLC LLC NFL LP LLC LP LLC LP Co. LLC LP LLC, 933 F.3d 1136 (9th Cir. 2019)

. . . NBC Universal, Inc. , 675 F.3d 1192, 1197 (9th Cir. 2012). . . . Brantley , 675 F.3d at 1198. . . . Brantley , 675 F.3d at 1197. . . .

EFFEX CAPITAL, LLC, v. NATIONAL FUTURES ASSOCIATION,, 933 F.3d 882 (7th Cir. 2019)

. . . No. 74-675, 49 Stat. 1491, 1491 (1936). . . .

RAM REZ- P REZ, v. P. BARR,, 934 F.3d 47 (1st Cir. 2019)

. . . Holder, 675 F.3d 9, 14 (1st Cir. 2012) ). . . .

IRIDESCENT NETWORKS, INC. v. AT T MOBILITY, LLC,, 933 F.3d 1345 (Fed. Cir. 2019)

. . . App'x at 675. . . .

UNITED STATES v. JOBE,, 933 F.3d 1074 (9th Cir. 2019)

. . . Burgard , 675 F.3d 1029, 1035 (7th Cir. 2012) (so recognizing). . . .

UNITED STATES v. GAMMELL, v., 932 F.3d 1175 (8th Cir. 2019)

. . . United States , 195 F.2d 673, 675-76 (8th Cir. 1952), "[i]n proscribing aiding and abetting, Congress . . . Mahkuk , 736 N.W.2d 675, 682 (Minn. 2007) ("[T]o prove that Mahkuk aided and abetted the shooting and . . .

PARENT PROFESSIONAL ADVOCACY LEAGUE M. W. a F. D. S. S. a S. Y. v. CITY OF SPRINGFIELD, MASSACHUSETTS J., 934 F.3d 13 (1st Cir. 2019)

. . . Coal. for Quality Assisted Living, Inc., 675 F.3d 149, 159 (2d Cir. 2012) (concluding that the record . . .

VALBRUNA SLATER STEEL CORPORATION, v. JOSLYN MANUFACTURING COMPANY,, 934 F.3d 553 (7th Cir. 2019)

. . . Citibank, N.A. , 852 F.3d 669, 675 (7th Cir. 2017). That state here is Indiana. . . .

DOE, v. MCKESSON, 935 F.3d 253 (5th Cir. 2019)

. . . Murphy Oil USA, Inc. , 686 F.Supp.2d 663, 675 (E.D. . . .

C. CHILDRESS, ALDA St. HLAA- StL A v. FOX ASSOCIATES, LLC, C. CHILDRESS, ALDA St. HLAA- StL A v. LLC,, 932 F.3d 1165 (8th Cir. 2019)

. . . Martin, 532 U.S. 661, 675, 121 S.Ct. 1879, 149 L.Ed.2d 904 (2001) ). . . .

KELLY, v. HONEYWELL INTERNATIONAL, INC., 933 F.3d 173 (2nd Cir. 2019)

. . . Docket Nos. 17-675(L) 17-2075(CON) August Term, 2018 United States Court of Appeals, Second Circuit. . . .

O NEAL, v. BALCARCEL,, 933 F.3d 618 (6th Cir. 2019)

. . . Id. at 44 (Page ID #675). . . .

ALBANY AIRPORT HIE, LLC HIE LLC, v. HANOVER INSURANCE GROUP, INC., 391 F. Supp. 3d 193 (N.D.N.Y. 2019)

. . . Co. of Pittsburgh, Pa., 25 N.Y.3d 675, 680, 16 N.Y.S.3d 21, 37 N.E.3d 78 (2015) (quoting Mount Vernon . . .

KODIAK OIL GAS USA INC. HRC LLC v. BURR S. EOG S., 932 F.3d 1125 (8th Cir. 2019)

. . . Stewart , 563 U.S. 247, 255, 131 S.Ct. 1632, 179 L.Ed.2d 675 (2011). . . .

O. CAMPOS, v. COOK COUNTY,, 932 F.3d 972 (7th Cir. 2019)

. . . Co. , 675 F.3d 709, 718 (7th Cir. 2012). . . .

D. TORRY, Q. I. v. CITY OF CHICAGO,, 932 F.3d 579 (7th Cir. 2019)

. . . Sawyer , 224 F.3d 675, 680 (7th Cir. 2000). . . .

BREDA, v. CELLCO PARTNERSHIP, d b a, 934 F.3d 1 (1st Cir. 2019)

. . . TruGreen, Inc., 675 Fed. . . .

K. W. P. By v. KANSAS CITY PUBLIC SCHOOLS In In, 931 F.3d 813 (8th Cir. 2019)

. . . Id. at 675. . . . App'x at 675. . . .

L. CRUMP, v. M. SAUL,, 932 F.3d 567 (7th Cir. 2019)

. . . Berryhill , 916 F.3d 671, 675-76 (7th Cir. 2019). . . .

FORCE, A. H. H. F. A. L. F. N. E. F, N. S. F. S. R. F. A. H. H. F. A. L. F. N. E. F. N. S. F. S. R. F. A. H. H. F. A. L. F. N. E. F, N. S. F. S. R. F. TZVI S. S. R. M. M. R. R. M. R. S. Z. R. S. S. R. M. M. R. R. M. R. S. Z. R. S. S. R. M. M. R. R. M. R. S. Z. R. v. FACEBOOK, INC., 934 F.3d 53 (2nd Cir. 2019)

. . . Rev. 675, 690-91 (2018) ; Anna Elisabeth Jayne Goodman, Note and Comment, When You Give a Terrorist a . . .

ATLAS BREW WORKS, LLC, v. P. BARR,, 391 F. Supp. 3d 6 (D.D.C. 2019)

. . . Lyons, 461 U.S. 95, 109, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983), and only where the plaintiff can "demonstrate . . .

UNITED STATES v. FELDMAN,, 931 F.3d 1245 (11th Cir. 2019)

. . . United States , 122 F.2d 675, 681 (5th Cir. 1941) (observing that fraud "is as old as falsehood and as . . .

UNITED STATES v. HENNESSEE,, 932 F.3d 437 (6th Cir. 2019)

. . . Brady , 988 F.2d at 675-77 (Jones, J., dissenting) ("In essence, the majority holds that Brady has had . . .

UNITED STATES v. GALECKI, v., 932 F.3d 176 (4th Cir. 2019)

. . . Tuomey Healthcare Sys., Inc. , 675 F.3d 394, 406 (4th Cir. 2012) ). . . . Drakeford , 675 F.3d at 406. . . .

MCCOTTRELL S. v. WHITE, 933 F.3d 651 (7th Cir. 2019)

. . . Servs. , 675 F.3d 650, 668 (7th Cir. 2012) (pepper spray); Lewis v. . . . Post , at 675. . . .

AL- BALUCHI a k a v. T. ESPER,, 392 F. Supp. 3d 46 (D.D.C. 2019)

. . . Circuit Court of Milwaukee County, 675 F.2d 946, 947-48 (7th Cir. 1982). . . .

PEARLMAN, v. BORGIA,, 275 So. 3d 1282 (Fla. App. Ct. 2019)

. . . Taylor , 933 So. 2d 675 (Fla. 1st DCA 2006). . . .

GORSS MOTELS, INC. a a E G, a a v. SAFEMARK SYSTEMS, LP,, 931 F.3d 1094 (11th Cir. 2019)

. . . Schor , 478 U.S. 833, 851, 106 S.Ct. 3245, 92 L.Ed.2d 675 (1986) (highlighting the constitutional significance . . .

UNITED STATES v. VALENZUELA,, 931 F.3d 605 (7th Cir. 2019)

. . . That is often a complicated question in any case, id. at 675, and it is one with which Corral does not . . .

SEVUGAN, v. DIRECT ENERGY SERVICES, LLC, a, 931 F.3d 610 (7th Cir. 2019)

. . . Schumacher , 844 F.3d 670, 675 (7th Cir. 2016) (setting forth principles governing assessment of complaint . . . Schumacher , 844 F.3d at 675 (citations omitted). . . .

IN RE BROWN,, 932 F.3d 162 (4th Cir. 2019)

. . . Tuomey Healthcare Sys., Inc. , 675 F.3d 394, 406 (4th Cir. 2012) ("[W]e note that our precedent is clear . . .

UNITED STATES v. DOE,, 932 F.3d 279 (5th Cir. 2019)

. . . Id. at 675. . . .

LUGO, v. A. BERRYHILL,, 390 F. Supp. 3d 453 (S.D.N.Y. 2019)

. . . Schweiker, 675 F.2d 464, 467 (2d Cir. 1982) (per curiam); see also Burton-Mann v. . . .

IN RE S. ANTONUCCI, v. S., 602 B.R. 618 (Bankr. E.D. Pa. 2019)

. . . Govani (In re Govani) , 509 B.R. 675, 684-686 (Bankr. N.D. . . .

TAUSCHER, v. PHOENIX BOARD OF REALTORS, INCORPORATED,, 931 F.3d 959 (9th Cir. 2019)

. . . Harkins Amusement Enters., Inc. , 603 F.3d 666, 675 (9th Cir. 2010). . . .

ANDERSON, v. CITY OF ROCKFORD,, 932 F.3d 494 (7th Cir. 2019)

. . . Bagley , 473 U.S. at 675, 105 S.Ct. 3375. . . .

D. HIGGINS, v. UNION PACIFIC RAILROAD CO., 931 F.3d 664 (8th Cir. 2019)

. . . Mills Fleet Farm, Inc., 245 F.3d 675, 681 (8th Cir. 2001) ("[T]he seriousness with which [employer] treated . . .

KOALA, v. KHOSLA,, 931 F.3d 887 (9th Cir. 2019)

. . . Stewart , 563 U.S. 247, 254-55, 131 S.Ct. 1632, 179 L.Ed.2d 675 (2011). . . .

E. CHAMBERS, v. DISTRICT OF COLUMBIA,, 389 F. Supp. 3d 77 (D.D.C. 2019)

. . . Dalton, 164 F.3d 671, 675 (D.C. . . .

L. TATUM, v. SOUTHERN COMPANY SERVICES, INCORPORATED,, 930 F.3d 709 (5th Cir. 2019)

. . . Precision Castparts Corp. , 726 F.3d 675, 683 (5th Cir. 2013). He fails to carry that burden. . . .

ZACARIAS v. STANFORD INTERNATIONAL BANK, LIMITED, L. v. S. S. v. a a v. De v. S. v. L. v. S. C. v. WGH De De De La v. De De De v. a a De v., 931 F.3d 382 (5th Cir. 2019)

. . . Green , 675 F.3d 503, 524 (5th Cir. 2012). 571 U.S. 377, 395-97, 134 S.Ct. 1058, 188 L.Ed.2d 88 (2014 . . .

BRAEBURN INC. v. UNITED STATES FOOD AND DRUG ADMINISTRATION,, 389 F. Supp. 3d 1 (D.D.C. 2019)

. . . Dep't of Educ. , 675 F.3d 769, 781 (D.C. Cir. 2012) (quoting Cnty. of L.A. v. . . . Petit , 675 F.3d at 781. . . .

IN RE G. QUEEN, Bi- LLC D. LLC, v. D. G., 602 B.R. 60 (B.A.P. 8th Cir. 2019)

. . . Ungar (In re Ungar ), 633 F.3d 675, 679 (8th Cir. 2011) ("We review the bankruptcy court's factual determinations . . .

IN RE HANNA, DMM s, v., 603 B.R. 571 (Bankr. S.D. Tex. 2019)

. . . Mans, 516 U.S. 59, 74, 116 S.Ct. 437, 133 L.Ed.2d 351 (1995) ; In re Bandi, 683 F.3d 671, 675 (5th Cir . . .

CORBETT, v. TRANSPORTATION SECURITY ADMINISTRATION,, 930 F.3d 1225 (11th Cir. 2019)

. . . Lyons, 461 U.S. 95, 101, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983) (quotations omitted). . . .

ACE AMERICAN INSURANCE COMPANY, a v. WATTLES COMPANY, a, 930 F.3d 1240 (11th Cir. 2019)

. . . Davies, 267 Ga.App. 675, 601 S.E.2d 363, 367 (2004) ("In construing a contract of insurance to ascertain . . .

N. Y. C. C. v. P. BARR,, 930 F.3d 884 (7th Cir. 2019)

. . . Holder , 733 F.3d 662, 675-76 (7th Cir. 2013) (en banc ). . . .

F. WORTHY, D. Co. v. CITY OF PHENIX CITY, ALABAMA,, 930 F.3d 1206 (11th Cir. 2019)

. . . Lyons , 461 U.S. 95, 102, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983) ); see also Lyons , 461 U.S. at 105, . . .

CAUSE OF ACTION INSTITUTE, v. INTERNAL REVENUE SERVICE,, 390 F. Supp. 3d 84 (D.D.C. 2019)

. . . FBI , 675 F. . . .

WATSO, C. H. C. P. v. LOUREY, E., 929 F.3d 1024 (8th Cir. 2019)

. . . Rushing , 898 F.2d 672, 675 (8th Cir. 1990) ("Nothing in the wording of Public Law 280 or its legislative . . .

NAVAJO NATION, a a k a v. SAN JUAN COUNTY, a, 929 F.3d 1270 (10th Cir. 2019)

. . . Wiggins , 675 F.3d 1134, 1139 (8th Cir. 2012) ("[D]eviations from [one person, one vote] are subject . . .

PARAMOUNT MEDIA GROUP, INC. v. VILLAGE OF BELLWOOD, 929 F.3d 914 (7th Cir. 2019)

. . . City of Chicago , 675 F.3d 743, 747 (7th Cir. 2012). . . .

MANNING v. CALDWELL, s FOR CITY OF ROANOKE s, 930 F.3d 264 (4th Cir. 2019)

. . . Lyons , 461 U.S. 95, 101-07, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983). . . .

ALARM DETECTION SYSTEMS, INCORPORATED, v. VILLAGE OF SCHAUMBURG, a, 930 F.3d 812 (7th Cir. 2019)

. . . Dist. of Du Page Cty., Ill. , 613 F.2d 675, 678 (7th Cir. 1980). . . . City of Chicago , 675 F.3d 743, 745 n.1 (7th Cir. 2012), the emails, like the complaint's allegations . . . Co. , 675 F.3d 709, 718 (7th Cir. 2012). D. . . .

CARELLO, v. AURORA POLICEMEN CREDIT UNION,, 930 F.3d 830 (7th Cir. 2019)

. . . Lyons , 461 U.S. 95, 105, 103 S.Ct. 1660, 75 L.Ed.2d 675 (1983). . . .

UNITED STATES v. MILLS,, 389 F. Supp. 3d 528 (E.D. Mich. 2019)

. . . Albertini, 472 U.S. 675, 680, 105 S.Ct. 2897, 86 L.Ed.2d 536 (1985). . . .

UNITED STATES v. STRUBBERG,, 929 F.3d 969 (8th Cir. 2019)

. . . Cooke , 675 F.3d 1153, 1155-56 (8th Cir. 2012). . . .

PENNSYLVANIA v. PRESIDENT UNITED STATES D. C., 930 F.3d 543 (3rd Cir. 2019)

. . . Hobby Lobby Stores, Inc., 573 U.S. 682, 134 S.Ct. 2751, 189 L.Ed.2d 675 (2014), the Supreme Court held . . .

STARR INDEMNITY LIABILITY COMPANY, v. BRIGHTSTAR CORP., 388 F. Supp. 3d 304 (S.D.N.Y. 2019)

. . . Co. of Pittsburgh, Pa., 25 N.Y.3d 675, 680, 16 N.Y.S.3d 21, 37 N.E.3d 78 (2015) ("An insurance agreement . . .

UNITED STATES v. PEREZ,, 929 F.3d 1106 (9th Cir. 2019)

. . . App. 3d 627, 633, 143 Cal.Rptr. 675 (1978) (rejecting a similar argument). In People v. . . .

UNITED STATES v. PETRUK, v., 929 F.3d 952 (8th Cir. 2019)

. . . Comstock, 531 F.3d 667, 675 (8th Cir. 2008) ; United States v. . . . See Comstock, 531 F.3d at 675-78 ; Gonzalez-Rodriguez, 239 F.3d at 951. . . .

UNITED STATES v. OSMAN, 929 F.3d 962 (8th Cir. 2019)

. . . Schaefer , 675 F.3d 1122, 1124 (8th Cir. 2012) ("While this court encourages detailed findings, it is . . .

UNITED STATES v. PEREZ,, 932 F.3d 782 (9th Cir. 2019)

. . . App. 3d 627, 633, 143 Cal.Rptr. 675 (1978) (rejecting a similar argument). In People v. . . .

MASTERMIND INVOLVEMENT MARKETING, INC. v. ART INSTITUTE OF ATLANTA, LLC,, 389 F. Supp. 3d 1291 (N.D. Ga. 2019)

. . . App. 231, 239, 659 S.E.2d 668, 675 (2008). . . .

RUSH, v. SAUL,, 389 F. Supp. 3d 957 (D.N.M. 2019)

. . . App'x 675, 678 (10th Cir. 2014) (quoting 20 C.F.R. Pt. 404, Subpt. P, App. 1, § 12.00(C)(4)). . . .

IN RE TS EMPLOYMENT, INC. S. TS v. LLP, 603 B.R. 700 (Bankr. S.D.N.Y. 2019)

. . . In re ABC , 190 B.R. at 675. . . .

UNITED STATES v. DANIELS,, 930 F.3d 393 (5th Cir. 2019)

. . . Daniels with intentional possession, his ultimate conviction was for aiding and abetting. 440 F.3d 672, 675 . . .

REINALT- THOMAS CORPORATION, d b a v. MAVIS TIRE SUPPLY, LLC,, 391 F. Supp. 3d 1261 (N.D. Ga. 2019)

. . . Drugs, Inc. , 675 F.2d 1160, 1167 (11th Cir. 1982), abrogated by Tobinick v. . . . Safeway , 675 F.2d at 1167 (citation omitted). . . .

LORENZO, v. P. BARR,, 929 F.3d 379 (6th Cir. 2019)

. . . Gonzales, 402 F.3d 668, 675 (6th Cir. 2005)). . . . Acquaah, 589 F.3d at 334 (citing Allabani, 402 F.3d at 675). . . .

TWEED- NEW HAVEN AIRPORT AUTHORITY, v. TONG,, 930 F.3d 65 (2nd Cir. 2019)

. . . Stewart , 563 U.S. 247, 252-53, 131 S.Ct. 1632, 179 L.Ed.2d 675 (2011) (considering suit by independent . . .

BRUCKER, v. CITY OF DORAVILLE, a, 391 F. Supp. 3d 1207 (N.D. Ga. 2019)

. . . Conradi, 675 F.2d 1212, 1217 (11th Cir. 1982) (citing Tumey and explaining that criminal justice must . . .

EVANS, v. SANDY CITY, a R. P. C. C. J. E. I- XX,, 928 F.3d 1171 (10th Cir. 2019)

. . . Albertini , 472 U.S. 675, 689, 105 S.Ct. 2897, 86 L.Ed.2d 536 (1985) ). . . .

UNITED STATES v. FLUTE,, 929 F.3d 584 (8th Cir. 2019)

. . . warrant a conviction of manslaughter." 1 William Oldnall Russell, A Treatise on Crimes and Misdemeanors 675 . . .

WILLIAMS Jr. v. BIG PICTURE LOANS, LLC LLC, Jr., 929 F.3d 170 (4th Cir. 2019)

. . . Chandia , 675 F.3d 329, 337 (4th Cir. 2012). . . .

EDGE, v. CITY OF EVERETT, a, 929 F.3d 657 (9th Cir. 2019)

. . . Albertini , 472 U.S. 675, 689, 105 S.Ct. 2897, 86 L.Ed.2d 536 (1985) ). . . .

WILLIAMS, v. LM GENERAL INSURANCE COMPANY,, 387 F. Supp. 3d 1366 (M.D. Fla. 2019)

. . . Case No. 6:19-cv-675-Orl-37LRH United States District Court, M.D. Florida, Orlando Division. . . .