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First National Bank of Grayson v. Whaley

Citations: 168 W. Va. 327; 284 S.E.2d 618; 32 U.C.C. Rep. Serv. (West) 1149; 1981 W. Va. LEXIS 754Docket: No. 15083

Court: West Virginia Supreme Court; December 1, 1981; West Virginia; State Supreme Court

Narrative Opinion Summary

In this case, the First National Bank of Grayson, Kentucky, pursued attorneys' fees following a default on a promissory note by W. R. W. Inc., with endorsements by Lewis and Rex Whaley. The note, valued at $10,000, contained a clause for reasonable attorneys' fees in the event of default. After partial payment and unsuccessful demands for the remaining balance, the bank initiated legal action. Prior to trial, the defendants sought to settle the outstanding balance and dismiss the bank's claim for attorneys' fees, which the court allowed. At the hearing, although the bank requested $1,896.33 in fees, the court only deemed $900 as reasonable but ultimately denied any award, referencing West Virginia's public policy. The bank contended its right to fees under the promissory note, necessitating a decision on whether West Virginia or Kentucky law was applicable. The court ruled that Kentucky law governed the contract, as it was executed and to be performed there. Kentucky law considers such fee provisions unenforceable due to public policy, leading the court to dismiss the bank's appeal and uphold the lower court's decision.

Legal Issues Addressed

Choice of Law in Contract Disputes

Application: The court applied Kentucky law to the promissory note because it was executed and to be performed in Kentucky, thus overriding West Virginia law.

Reasoning: The court needed to decide whether to apply West Virginia or Kentucky law. It concluded that Kentucky law applied, as the note was executed in Kentucky and the obligations were to be performed there.

Enforceability of Attorneys' Fees Provisions

Application: The court determined that under Kentucky law, provisions for attorneys’ fees in promissory notes are unenforceable due to public policy.

Reasoning: Under Kentucky law, provisions for attorneys’ fees in promissory notes are deemed unenforceable due to public policy, as established in precedent cases.

Public Policy Consideration in Legal Fees

Application: Despite finding the requested attorneys' fees reasonable, the court denied the award based on public policy considerations against such fees.

Reasoning: During the subsequent hearing, the bank claimed $1,896.33 in attorneys’ fees but the court determined $900 to be reasonable yet denied any fee award, citing public policy in West Virginia against such fees.