In the 1892 case Means v. Bank of Randall, the U.S Supreme Court ruled in favor of the defendant, The Bank of Randall. The plaintiff, Mr. Means had sued for damages after he was denied access to his safety deposit box at the bank during a period when it was under receivership due to financial difficulties. He claimed that this denial constituted a breach of contract and sought compensation for losses incurred as a result. However, upon review by Justice David Brewer on behalf of an unanimous court, it was determined that while there may have been inconvenience caused by not being able to access his valuables immediately; no actual damage or loss could be proven since all items were eventually returned intact once normal operations resumed at the bank.

In the dissenting opinion for Means v. Bank of Randall, Justice Brewer argued that the bank should not be held liable for the loss incurred by Mr. Means due to his own negligence in failing to promptly examine his returned checks and notify the bank of any discrepancies. He contended that it was unreasonable to expect banks to bear responsibility indefinitely for forged endorsements on checks they have paid out, especially when customers have ample opportunity and are better positioned than banks themselves to detect such frauds early on through regular examination of their accounts' activity. The majority's ruling, he feared, would place an undue burden on banking institutions and disrupt established commercial practices without providing a corresponding benefit in terms of enhanced security against forgery or fraud.