id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-27445	Sullivan, Jr., Frank	Business, Banking, and Contract Law	2023	43	.pdf	application/pdf	18968	1138	66	This Article will not itemize every banking, business, and contract law case decided during the Survey Period. Id. 2023] BANKING, BUSINESS, AND CONTRACT LAW 673 the Crime Victim’s Relief Act (“CVRA”).27 The trial court entered a judgment of approximately $322,000 (including interest and attorney’s fees) in favor of AFC on its breach of contract claim, but the trial court held that Metro did not commit conversion.28 Both sides appealed.29 Metro argued that the trial court had miscalculated damages by including a $79,000 item twice.30 AFC conceded the point, and the Court of Appeals reduced the amount of the award accordingly.31 For its part, AFC contended the trial court had committed clear error in not finding Metro guilty of conversion, thereby opening the door to treble damages under the CVRA.32 The trial court judge had found that AFC had not proved conversion even by a preponderance of the evidence.33 The Court of Appeals agreed, and its analysis is instructive.34 Judge Najam recited precedent to the effect that “money may be the subject of a conversion action only if it is ‘a determinate sum with which the defendant was entrusted to apply to a certain purpose.’”35	cache/inlawrev-27445.pdf	txt/inlawrev-27445.txt