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Laclede Bank v. Schuler was a case heard by the United States Supreme Court in which the Court was asked to determine whether a bank could be held liable for the wrongful acts of its employees. The case arose when the Laclede Bank of St. Louis, Missouri, was sued by a customer, Schuler, for damages resulting from the bank's negligence in failing to properly supervise its employees. Schuler alleged that the bank's employees had fraudulently induced him to invest in a certain stock, and that the bank had failed to properly supervise its employees, resulting in Schuler's losses. The Supreme Court held that the bank could be held liable for the wrongful acts of its employees. The Court reasoned that the bank had a duty to exercise reasonable care in supervising its employees, and that it had failed to do so. The Court also noted that the bank had a duty to act in good faith and with due care in its dealings with its customers, and that it had failed to do so in this case. The Court concluded that the bank was liable for the damages suffered by Schuler as a result of its negligence.
Justice Field delivered the dissenting opinion in Laclede Bank v. Schuler, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that the bank had a valid lien on all of Schuler's property, including his future wages, which were not exempt from execution under Missouri law at the time of judgment. The majority held that because Schuler had already received some of his wages before they could be attached by process of garnishment or otherwise seized by court order, those funds were no longer subject to attachment as part of any subsequent judgment against him. Justice Field disagreed with this conclusion and asserted that such an interpretation would lead to injustice for creditors who have obtained judgments prior to their debtors receiving their salaries or other income sources; it also would allow debtors to evade payment on debts owed simply by spending money quickly after receiving it rather than holding onto it until a creditor can attach it through legal means. Therefore, he concluded that since there was nothing in Missouri law prohibiting wage attachments when Laclede Bank obtained its judgment against Schuler, its lien extended over all his property - including future wages - regardless if he had already been paid them prior to being served with notice regarding garnishment proceedings initiated by Laclede Bank