In the case of Gallaway v. Fort Worth Bank in 1901, the U.S. Supreme Court ruled on a dispute involving a promissory note and its payment terms. The plaintiff, Gallaway, claimed that he had paid off his debt to the defendant bank but was still being pursued for further payments. He argued that this constituted harassment and sought damages from the bank for causing him emotional distress. The court found in favor of Fort Worth Bank, ruling that it was within their rights as creditors to pursue repayment until they were satisfied with proof of full settlement by Gallaway. They also held that any alleged emotional distress caused by these actions did not constitute grounds for legal action against them. This decision reinforced creditor's rights under contract law while also setting precedent regarding claims of emotional distress resulting from financial disputes.

The dissenting opinion in the case of Gallaway v. Fort Worth Bank argued that the majority's decision was inconsistent with previous rulings and legal principles regarding negotiable instruments. The dissent took issue with the court's interpretation of "due diligence" as it pertained to a bank's responsibility to notify an endorser about dishonored checks, arguing that there should be no obligation for immediate notification if there is no harm or loss caused by delay. They also disagreed with the majority’s view on what constitutes reasonable time, asserting that this should be determined based on each individual circumstance rather than setting a rigid standard applicable universally. Furthermore, they contended that any negligence from part of endorsers could not absolve banks from their responsibilities under law.