Mont. Code Ann. » TITLE 30. TRADE AND COMMERCE · CHAPTER 1. UNIFORM COMMERCIAL CODE GENERAL PROVISIONS · Part 1. Short Title, Construction, Application, and Subject Matter of the Code
Montana Code Annotated

Mont. Code Ann. § 30-1-103 (2026)

Supplementary General Principles Of Law Applicable

✓ current as of May 2026
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  1. MCA Contents
  2. TITLE 30
  3. CHAPTER 1
  4. Part 1
  5. 30-1-103 Supplementary general principles of law applicable

TITLE 30. TRADE AND COMMERCE

CHAPTER 1. UNIFORM COMMERCIAL CODE GENERAL PROVISIONS

Part 1. Short Title, Construction, Application, and Subject Matter of the Code

Supplementary General Principles Of Law Applicable

30-1-103. Supplementary general principles of law applicable. Unless displaced by the particular provisions of this code, the principles of law and equity, including the law merchant and the law relative to capacity to contract, principal and agent, estoppel, fraud, misrepresentation, duress, coercion, mistake, bankruptcy, or other validating or invalidating cause shall supplement its provisions.

History: En. Sec. 1-103, Ch. 264, L. 1963; R.C.M. 1947, 87A-1-103.

Notes of Decisions
Cited in 13 cases, 1981–2019 · leading case: S & P Brake Supply, Inc. v. STEMCO LP, 2016 MT 324, 385 P.3d 567.
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S & P Brake Supply, Inc. v. STEMCO LP, 2016 MT 324, 385 P.3d 567. · cites it 22× “The statute does not explicitly name promissory estoppel as an exception. But a separate UCC provision, titled “Supplementary general principles of law applicable,” provides, “Unless displaced by the particular provisions of this code, the principles of law and equity, including…”
Kapor v. RJC Inv., Inc., 2019 MT 41, 434 P.3d 869. · cites it 16× “" Section 30-1-103, MCA. The Official Comments to § 30-1-103, MCA, provide that "while principles of common law and equity may supplement provisions of the [U.”
Valley Bank v. Hughes, 2006 MT 285, 147 P.3d 185. · cites it 10× “” ¶20 The District Court rested its conclusion on its interpretation of § 30-1-103, MCA, which reads as follows: Unless displaced by the particular provisions of this code, the principles of law and equity, including the law merchant and the law relative to capacity to contract,…”
Stapleton v. First Sec. Bank, 675 P.2d 83 (Mont. 1983). · cites it 9× “We hold that absent proof to the contrary, Eleanor may recover one-half the amount of the checks.”
Norwest Bank Billings v. Murnion, 684 P.2d 1067 (Mont. 1984). · cites it 6× “Section 30-1-103, MCA. The loader in this case comes within the Code definition of “goods.”
Crystal Springs Trout Co. v. First State Bank, 732 P.2d 819 (Mont. 1987). · cites it 5× “These six notes were ones which were given by CSTC and co-signed by the CSTC principals in reliance on Wallander's misrepresentations as to the availability of interim financing.”
Avanta Fed. Credit Union v. Shupak, 2009 MT 458, 223 P.3d 863. · cites it 3× “Section 30-1-103, MCA. Applying equitable estoppel as argued by Shupak would displace the clear statutory provision of a bank’s right to charge back, and an equitable remedy cannot do so.”
Daniels-Sheridan Fed. Credit Union v. Bellanger, 2001 MT 235, 36 P.3d 397. · cites it 4× “Specifically, §§ 30-9-301 and -302, MCA (1999), provide generally that a financing statement is required to perfect all security interests and an unperfected security interest is subordinate to the rights of a person statutorily entitled to priority.”
Nw. Potato Sales, Inc. v. Beck, 678 P.2d 1138 (Mont. 1984). · cites it 3× “The UCC expressly mentions estoppel as one of the general principles of law that supplement the UCC (Section 30-1-103, MCA), unless other parts of the UCC expressly displace that principle.”
Conagra, Inc. v. Nierenberg, 2000 MT 213, 7 P.3d 369. · cites it 2× “¶42 This Court has, however, dealt at length with “judicial admissions” in other contexts, and we conclude that the prevailing principles for such admissions control the admissions exception under § 30-2-20l(3)(b), MCA, and must therefore form the lens through which non-Montana…”
First Nat'l Bank v. Nunn, 628 P.2d 1110 (Mont. 1981). · cites it 3× “Gladys also testified that he received another $200 in cash from the proceeds of his paycheck. About a week later, Paul went to his employer and alleged that his paycheck had been stolen and his signature forged.”
Schlenz v. John Deere Co., 511 F. Supp. 224 (D. Mont. 1981). “§ 30-1-103, M.C.A. A basic principle of Montana principal and agent law is that An oral authorization is sufficient for any purpose, except that an authority to enter into a contract required by law to be in writing can only be given by an instrument in writing.”
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Mont. Code Ann. § 30-1-103(1): 1 case
Stapleton v. First Sec. Bank, 675 P.2d 83 (Mont. 1983). “We hold that absent proof to the contrary, Eleanor may recover one-half the amount of the checks.”
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