In the 1898 case of Merrill v. National Bank of Jacksonville, the United States Supreme Court ruled on a dispute involving a promissory note and its endorsement. The plaintiff, Merrill, had received an endorsed promissory note from one Mr. Drew as security for loans he provided to Drew's business ventures in Florida. When Drew defaulted on his obligations under the note, Merrill sought payment from the defendant bank which had originally issued and accepted endorsement of the note. The main issue before court was whether or not this particular type of transaction constituted "negotiation" under relevant law - if so, then liability would extend to all parties who endorsed (or signed) it along its path; if not, only those directly involved in defaulting could be held accountable. The Supreme Court ultimately decided that such transactions did indeed constitute negotiation according to established legal principles and precedents at that time. Therefore they found in favor of Merrill: both original issuer (the bank) and subsequent endorser (Drew) were liable for repayment because they effectively guaranteed payment by endorsing it over to another party.

In the dissenting opinion for Merrill v. National Bank of Jacksonville, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of equity. He contended that a bank should not be able to profit from its own negligence or wrongdoing by charging fees on checks it had wrongfully dishonored due to an error in bookkeeping. Instead, he believed that banks should bear responsibility for their mistakes and compensate customers accordingly. Furthermore, he disagreed with the majority's interpretation of Florida law regarding banking transactions and asserted that it did not absolve banks from liability in such cases. Overall, his dissent emphasized fairness towards customers and accountability for financial institutions.