Higgins was a used-car dealer. He purchased a Corvette, giving the seller a draft drawn by him on the First State Bank of Albertville in the amount of $8,115. This draft was later presented by the seller to the bank for payment.

Meanwhile, Higgins sold the car to Holsonback, who paid with a draft on the Albertville National Bank in the amount of $8,225. When the Albertville National Bank requested Holsonback to pay the draft, he refused, claiming that there was a problem with the certifi cate of title. The issue was raised as to whether, under the Uniform Commercial Code, negotiable instruments can be issued conditionally. Did Holsonback have the right to withhold payment on the draft because of the problem with the certifi cate of title? [ Holsonback v. First State Bank, 394 So. 2d 381

(Alabama).]