In any event, the court in G R Corp. was not interpreting the same section of the U.C.C. and did not face the precise issue that we decide today, and so the decision there is not dispositive of this case. Furthermore, since that opinion, there has been substantial authority rejecting the view announced in G R Corp. See, e.g., Southern Contract Carpet, Inc. v. County Nat'l Bank, 528 So.2d 42, 43-44 (Fla.Dist.Ct.App. 1988); First Nat'l Bank v. La Sara Grain Co., 646 S.W.2d 246, 251-52 (Tex.Ct.App. 1982), aff'd in part, rev'd in part, 673 S.W.2d 558 (Tex. 1984) (affirming interpretation of ยง 4-406); Rascar, Inc. v. Bank of Oregon, 87 Wis.2d 446, 275 N.W.2d 108, 111 n. 1 (1978); King of All Mfg., Inc. v. Genesee Merchants Bank Trust Co., 69 Mich.App. 490, 245 N.W.2d 104 (1976); Fireman's Fund Ins. Co. v. National Westminster Bank U.S.A., 543 N.Y.S.2d 604, 605-06 (N.Y.Sup.Ct. 1988); Provident Sav. Bank v. United Jersey Bank, 207 N.J.Super. 303, 504 A.2d 135, 140-41 (1985). But see, Wolfe v. University Nat'l Bank, 270 Md. 70, 310 A.2d 558, 560 (1973).
The trial court agreed with the bank, and dismissed the complaint. The bank relied on Southern Contract Carpet, Inc. v. County National Bank of South Florida, 528 So.2d 42 (Fla. 3d DCA 1988), in arguing that Section 674.406(4) contains a statute of limitations. However, Southern Contract Carpet focused on the definition of an unauthorized signature under the statute.
Arkansas: Spears Carpet Mills, Inc. v. Century National Bank of New Orleans, 6 UCC Rep.Serv.2d 503, 505, 85 BR 86 (W.D.Ark. 1988), applying Louisiana law; Cooley v. First Nat'l. Bank of Little Rock, Arkansas, 276 Ark. 387, 635 S.W.2d 250, 252 (1982); Pine Bluff Nat'l. Bank v. Kesterson, 257 Ark. 813, 520 S.W.2d 253, 258 (1975). Florida: Burdine-Coakley v. Capital Bank, 542 So.2d 1019, 1020 (Fla.App. 1989); Southern Contract Carpet, Inc. v. County National Bank of South Florida, 528 So.2d 42, 43 (Fla.App. 1988). Louisiana: Amico Centennial Ins. Agency, Inc. v. First Nat'l. Bank of St. Bernard Parish, 543 So.2d 527, 529 (La.App. 1989).
PER CURIAM. Affirmed. Southern Contract Carpet, Inc. v. County National Bank of South Florida, 528 So.2d 42 (Fla. 3d DCA 1988); Space Distributors, Inc. v. Flagship Bank of Melbourne, N.A., 402 So.2d 586 (Fla. 5th DCA 1981); Sections 674.406(1) 674.406(4), Florida Statutes (1983).
Some cases hold that where the customer directed the bank to pay only checks with two signatures, one signature checks were an unauthorized signature, and the one year time limit in ยง 4-406(4) applies. Pine Bluff National Bank v. Kesterson, 257 Ark. 813, 520 S.W.2d 235 (1975); Cooley v. First National Bank of Little Rock, 276 Ark. 387, 635 S.W.2d 250 (1982);King of All Manufacturing, Inc. v. Genesee Merchants Bank Trust Co., 69 Mich. App. 490, 245 N.W.2d 104 (1976); Rascar, Inc. v. Bank of Oregon, 87 Wis.2d 446, 275 N.W.2d 108 (1978), Jacoby Transport Systems, Inc. v. Continental Bank, 277 Pa. Super. 440, 419 A.2d 1227 (1980); Southern Contract Carpet, Inc. v. County National Bank of South Florida, 528 So.2d 42 (Fla. 3rd DCA 1988); Provident Savings Bank v. United Jersey Bank, 207 N.J. Super. 303, 504 A.2d 135 (1985);First National Bank of Mercedes v. LaSara Grain Co., 646 S.W.2d 246 (Tex.Civ.App. 1982). This line of cases takes the view that the meaning of "unauthorized signature" encompasses more than forgeries or alterations for a check signed by the wrong person, and also includes checks with a single signature since the customer had not authorized the bank to pay one signature checks.