Virtually every business has been faced with the dilemma of receiving a customer's check for partial payment of a debt, only to realize that the check includes a notation stating that the amount constitutes "full and final" payment. The party receiving such a check generally has two options: accepting and cashing the check, or returning the check to the debtor with a demand for full payment. Obviously, the best alternative would be to accept the check as partial payment and pursue the balance. Most jurisdictions construe cashing such a check as a "full accord and satisfaction," which precludes additional claims or suits for the unpaid balance. In essence, the partial payment becomes a settlement offer, and, if it
