Robert Triffin, who makes a living of buying bounced checks and trying to recover as a holder in due course, has resorted to the courts so often and so perniciously that a New Jersey appeals panel evidently feels enough is enough.

Though finding his fabrication of check assignments did not make Triffin liable for common law fraud, the judges said his actions might constitute a fraud on the court itself. On Thursday, they remanded the case, Triffin v. Automatic Data Processing Inc., A-6986-03, to the trial court for a hearing on the possible imposition of sanctions.