Plaintiff sued on a certificate of deposit and a certified check, the former being issued by the defendant bank in 1905 and the latter being certified in 1919. Both were negotiated in 1937 and presented for payment the next day. Defendant pleaded the ten year statute of limitations as a bar. Held, at common law the statute of limitations did not operate on demand certificates of deposit until demand had been made, and section 70 of the Negotiable Instrument Law does not alter this common-law requirement. This applies also to certified checks, for they are substantially the same as certificates of deposit. Dean v. Iowa-Des Moines Nat. Bank & Trust Co., (Iowa 1938) 281 N. W. 714.
Michigan Law Review,
BILLS AND NOTES - EFFECT OF STATUTE OF LIMITATIONS ON DEMAND CERTIFICATES OF DEPOSIT AND CERTIFIED CHECKS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol37/iss8/15