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Mademoiselle Fashions, Inc. v. Buccaneer Sportswear, Inc.

Citations: 11 Ark. App. 158; 668 S.W.2d 45; 1984 Ark. App. LEXIS 1523Docket: CA 83-238

Court: Court of Appeals of Arkansas; April 18, 1984; Arkansas; State Appellate Court

Narrative Opinion Summary

This case concerns an appeal arising from a commercial dispute over an unpaid balance related to clothing orders. The appellant, having received merchandise and subsequently returned several items, was credited by the appellee for the returned goods. The appellant then remitted a check for an amount corresponding to a specific invoice, accompanied by language purporting to settle all outstanding debts. Despite this, a balance remained unpaid, prompting the appellee to initiate collection proceedings. The appellant defended by asserting accord and satisfaction, contending that the check and its accompanying language constituted a complete settlement of the account. The trial court rejected this defense, finding that there was no bona fide dispute over the remaining balance after credits were applied and that the payment corresponded only to a single invoice rather than the entire debt. The court concluded that the appellee’s acceptance of the check did not discharge the remaining obligation. On appeal, the court affirmed the trial court’s ruling, holding that the requirements for accord and satisfaction were not met and that the remaining balance was properly subject to collection.

Legal Issues Addressed

Accord and Satisfaction—Requirement of Bona Fide Dispute

Application: The court held that an accord and satisfaction defense fails where there is no genuine dispute as to the amount owed after all credits have been accounted for.

Reasoning: Key legal precedents state that for an accord and satisfaction to exist, there must be a genuine dispute over the amount owed, and the party accepting payment must understand it as full settlement of the debt.

Appellate Review of Accord and Satisfaction Rulings

Application: The appellate court will affirm the trial court’s determination regarding accord and satisfaction if there is no error in applying the relevant legal standards.

Reasoning: The appellate court affirmed the trial court's ruling, finding no error in its determination regarding the accord and satisfaction.

Effect of Crediting Returned Merchandise on Disputed Amount

Application: Once credits are issued for returned or disputed merchandise, the remaining balance constitutes the undisputed amount.

Reasoning: The trial court found no good-faith basis for the appellant to dispute the amount owed after receiving credits for the returned merchandise.

Interpretation of Payment as Full Settlement

Application: A check sent for the amount of a specific invoice, even if accompanied by language suggesting full satisfaction, does not constitute full settlement if it only matches a portion of the total debt.

Reasoning: The check's amount matched a specific invoice, suggesting it was a payment rather than a settlement of all debts.