Fourth National Bank of New York v. Francklyn was a United States Supreme Court case that addressed the issue of whether a bank could be held liable for the wrongful acts of its officers. The case arose when the Fourth National Bank of New York refused to honor a check drawn on its account by one of its officers, who had been authorized to draw checks on the bank's account. The bank argued that it was not liable for the officer's actions because it had not authorized the check. The Supreme Court held that the bank was liable for the officer's actions because it had authorized him to draw checks on its account. The Court reasoned that the bank had a duty to exercise reasonable care in the selection of its officers and to supervise their activities. The Court also held that the bank was liable for the officer's actions because it had failed to exercise reasonable care in the selection and supervision of its officers. In conclusion, the Supreme Court held that the Fourth National Bank of New York was liable for the wrongful acts of its officers because it had failed to exercise reasonable care in the selection and supervision of its officers. The Court's decision established that banks are liable for the wrongful acts of their officers and must exercise reasonable care in the selection and supervision of their officers.

Justice Field delivered the dissenting opinion in Fourth National Bank of New York v. Francklyn, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that the bank had a right to set off its debt against any money due from it to Francklyn, as provided by law. The court held that this could not be done because there was no mutuality between them; however, Field disagreed with this conclusion and stated that such an interpretation would render many laws useless. He further argued that if two parties are mutually indebted to each other then they have a right to set off their debts against one another regardless of whether or not they are both liable for damages on either side of the transaction. In addition, he noted how courts have long recognized this principle when dealing with cases involving mutual debts owed by different persons or corporations who may also be liable for damages on either side of the transaction. Finally, Justice Field concluded his dissent by stating his belief that allowing banks like Fourth National Bank of New York to exercise their legal rights under these circumstances is essential in order for justice and equity to prevail in our society today