Sixth Circuit -- Carol Metz v. Unizan Bank

Carol Metz v. Unizan Bank
James Loyd v. Huntington National Bank  
Billy Blair v. Bank One 
David McKinney v. Nick Ludwick 

A UCC "properly payable" claim against the bank issuer of checks used in a Ponzi scheme is not considered an action for conversion under the Ohio statute of limitations.  (Which would have ticked from discovery, not conduct.)

SOL ran from the first discovery that something wasn't right (cessation of interest payments), not the full discovery of facts.

Though plaintiffs did not caption petition as securities fraud, the actual nature of the investments means that the securities fraud statutory SOL applies, not the common law rule.

Court retains jurisdiction over claims after denial of class certification.

Settlement of claims against a party releases any respondeat superior claims against their supervisor.