According to the Uniform Commercial Code,a party may be a holder in due course of a non-negotiable instrument.

Uniform Commercial Code

The Uniform Commercial Code (UCC) is a comprehensive set of laws governing all commercial transactions in the United States, intended to harmonize the law of sales and other commercial transactions.

Non-negotiable Instrument

A document or contract that cannot be transferred or assigned from one person to another in a way that the receiver obtains the legal right to it.

Holder in Due Course

A party that has acquired a negotiable instrument in good faith and for consideration, thereby obtaining certain rights free of many defenses available to the original parties.