Jenness v. Citizens' National Bank of Rome is a United States Supreme Court case that was decided in 1884. The case involved a dispute between a bank and a customer over the bank's refusal to honor a check. The customer, Jenness, had deposited a check with the bank, but the bank refused to honor it because the check was not endorsed by the payee. Jenness sued the bank for breach of contract, claiming that the bank had agreed to honor the check when it accepted it for deposit. The Supreme Court held that the bank was not liable for breach of contract because the bank had not agreed to honor the check without the payee's endorsement. The Court reasoned that the bank had not assumed any obligation to honor the check, and that the customer had not been misled into believing that the bank would honor the check without the payee's endorsement. The Court also held that the bank was not liable for negligence because the bank had not acted unreasonably in refusing to honor the check. In conclusion, the Supreme Court held that the bank was not liable for breach of contract or negligence in refusing to honor the check without the payee's endorsement. The Court reasoned that the bank had not assumed any obligation to honor the check, and that the customer had not been misled into believing that the bank would honor the check without the payee's endorsement.

Justice Field delivered the dissenting opinion in Jenness v. Citizens' National Bank of Rome, arguing that the majority's decision was contrary to established law and precedent. He argued that a bank is not liable for its own negligence when it pays out funds on forged checks or notes unless it has knowledge of the fraud at the time payment is made. The Court had previously held in similar cases that banks are only liable if they have actual knowledge of any fraudulent activity prior to making payment, regardless of whether they were negligent in failing to discover such frauds before paying out money. Justice Field further noted that even if there had been some degree of negligence on behalf of the bank, this would not be sufficient grounds for imposing liability since no damages could be proven as a result thereof; rather, he argued that proof must exist showing actual knowledge by the bank prior to making payment in order for liability to attach. In conclusion, Justice Field concluded his dissent by noting his disagreement with both parts of the majority's ruling: firstly because their interpretation ran counter existing legal principles and secondly because they failed to provide evidence demonstrating actual knowledge on part of defendant-bank prior to making payments which would justify imposition thereof