In the 1892 case of Metropolitan Bank v. St. Louis Dispatch Company, the U.S Supreme Court examined whether a bank could sue for libel based on an article published by a newspaper that allegedly damaged its reputation and caused financial harm. The St. Louis Dispatch had published an article suggesting that the Metropolitan Bank was in poor financial condition, which led to significant withdrawals from customers who feared for their deposits' safety. The bank sued for libel, claiming damages due to loss of business and damage to its reputation. The court ruled in favor of the newspaper company stating that while false statements were made about the bank's solvency status, it did not constitute malice as required under defamation law at that time because there was no evidence showing intent or reckless disregard towards truthfulness on part of St.Louis Dispatch Company when publishing said information about Metropolitan Bank's fiscal health.

In the dissenting opinion for Metropolitan Bank v. St. Louis Dispatch Company, it was argued that the bank should not be held liable for damages resulting from a libelous article published by the newspaper about one of its customers. The justice believed that while the bank did provide information to the newspaper, they were under no obligation to ensure its accuracy or prevent potential harm caused by its publication. They also noted that there was no evidence showing malicious intent on behalf of the bank in providing this information and therefore, they should not be held responsible for any damage suffered by their customer as a result of this publication. This view suggests an interpretation where banks are protected from liability when acting in good faith without malice even if their actions inadvertently lead to harm.