Heather Washington v. VyStar Credit Union
Heather Washington brought a breach of contract claim against VyStar Credit Union alleging overdraft fees were charged on signature-based debit card transactions even though her available balance was sufficient when she presented her card. Washington argued overdraft determinations were made at authorization, not at the time VyStar paid the merchant at settlement. The trial court dismissed, finding the account agreement unambiguously provided that overdrafts are determined at payment to the merchant. The Fifth DCA affirmed, holding that authorization and payment are distinct events and an authorization hold does not obligate VyStar to sequester those funds exclusively for the originating transaction.
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