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Exchange National Bank of Pittsburgh v. Third National Bank of New York was a case heard by the United States Supreme Court in 1884. The case involved a dispute between two banks over a check that had been issued by the Third National Bank of New York. The check was made payable to the Exchange National Bank of Pittsburgh, but the Third National Bank of New York refused to honor the check, claiming that it had been issued without sufficient funds in the account. The Exchange National Bank of Pittsburgh argued that the Third National Bank of New York had a duty to honor the check, as it had been issued in good faith and with sufficient funds in the account. The Supreme Court agreed with the Exchange National Bank of Pittsburgh, ruling that the Third National Bank of New York had a duty to honor the check. The Court held that the Third National Bank of New York had a duty to honor the check, as it had been issued in good faith and with sufficient funds in the account. The Court also held that the Third National Bank of New York was liable for any damages caused by its refusal to honor the check. The ruling in this case established the principle that banks have a duty to honor checks that are issued in good faith and with sufficient funds in the account. This principle has been applied in numerous cases since then, and is still an important part of banking law today.
In Exchange National Bank of Pittsburg v. Third National Bank of New York, the Supreme Court was asked to determine whether a bank could be held liable for failing to pay on an instrument that it had accepted and certified without any knowledge or notice that the signature on the instrument was forged. The majority opinion found in favor of the defendant bank, holding that since there was no evidence presented at trial showing actual knowledge or notice by the defendant bank, they were not liable for payment on such instruments. Justice Field dissented from this decision arguing that banks should have a duty to exercise reasonable care when accepting and certifying checks in order to protect against fraud and forgery; thus if negligence can be proven then liability should attach regardless of lack of actual knowledge or notice. He further argued that banks are expected to use greater caution than ordinary individuals because they deal with large sums money which makes them more susceptible to fraudulent activity; therefore their standard must also be higher when dealing with these matters.