In the case of First National Bank of Grand Forks v. Anderson in 1898, the U.S Supreme Court ruled on a dispute involving a bank and its customer over an unpaid loan. The plaintiff, First National Bank of Grand Forks, had sued John Anderson to recover money he owed them from a promissory note that was overdue by several years. However, Anderson claimed that he had already paid off his debt through various transactions with the bank which were not properly credited to his account due to negligence or fraud on part of the bank's officers. The court held that while banks are generally presumed to have correctly performed their duties unless proven otherwise, this presumption could be rebutted if there is evidence showing misconduct or error by the bank officials. In this case however, it found no such proof against First National Bank and therefore upheld its claim against Anderson for repayment of his outstanding loan amount plus interest.

The dissenting opinion in the case of First National Bank of Grand Forks v. Anderson argued that the majority's decision was inconsistent with previous rulings and principles regarding bank liability for forged checks. The dissent contended that a bank should not be held liable if it pays out on a check bearing a forgery indistinguishable from an authentic signature, especially when there is no negligence or bad faith involved on part of the bank. It further stated that placing such responsibility on banks would create an undue burden and could potentially disrupt banking operations nationwide. Additionally, it pointed out inconsistencies between this ruling and prior decisions which had established different standards for determining liability in cases involving forged instruments.