In the 1995 case, Bank One Chicago, N.A. v. Midwest Bank & Trust Company, the U.S Supreme Court addressed a dispute between two banks over priority of security interests in a debtor's account. The debtor had granted both banks security interest in its accounts receivable but defaulted on its obligations to both institutions. The primary issue was whether Article 9 or Article 4A of the Uniform Commercial Code (UCC) governed this situation and determined which bank had priority to claim against the account funds for repayment of debt owed by their mutual customer. The court ruled that Article 4A applied because it specifically dealt with fund transfers while Article 9 generally covered secured transactions without specific reference to fund transfers like those at issue here. As such, under UCC rules governing wire transfer law (Article 4A), Midwest Bank’s right as an intermediary bank took precedence over any conflicting claims from other creditors including Bank One who claimed prior perfected security interest under general provisions of UCC (Article-9). Therefore, Midwest was entitled to set off amounts due from defaulting customer against funds transferred through it before paying remaining balance into his account where other creditors could reach them.

In the dissenting opinion for Bank One Chicago, N.A. v. Midwest Bank & Trust Company, Justice Scalia disagreed with the majority's interpretation of Article 4A of the Uniform Commercial Code (UCC). He argued that under UCC 4A-207, a bank could not be held liable if it followed "reasonable commercial standards" and acted in good faith when processing wire transfers. The majority had ruled that Bank One was liable because it did not follow its own security procedures; however, Scalia contended this was irrelevant as long as they adhered to reasonable commercial standards overall. Furthermore, he criticized the court's decision to remand back to state courts on an issue where uniformity across states is crucially important - namely banking law - which would potentially lead to different interpretations and outcomes in different jurisdictions.