Halifax Corp. v. First Union National Bank

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that Title 8.4, which “delineates the rights of a customer against its drawee bank for the improper payment of checks drawn on the customer’s account,” displaces a common law contract claim
• recognizing that “when the General Assembly includes specific language in one section of a statute, but omits that language from another section of the statute, we must presume that the exclusion of the language was intentional”
• stating that rules of statutory interpretation dictate that when specific language is included in one section but omitted in another section courts “presume that the exclusion of the language was intentional”
• “[T]he intention ofthe legislature . . . must be gathered from the words used, unless a literal construction would involve a manifest absurdity.” (quoting Watkins v. Hall, 172 S.E. 445, 447 (Va. 1934))
• “[W]hen the General Assembly includes specific language in one section of a statute, but omits that language from another section of the statute, we must presume that the exclusion of the language was intentional.”
• “[W]hen the General Assembly includes specific language in one section of a statute, but omits that language from another section of the statute, we must presume that the exclusion of the language was intentional.”

Source: CourtListener parenthetical corpus (CC0).