In the 1892 case of Moses v. Lawrence County Bank, the United States Supreme Court was tasked with determining whether a bank could be held liable for accepting and cashing fraudulent checks. The plaintiff, Moses, alleged that he had been defrauded by an individual who presented forged checks to the defendant's bank (Lawrence County Bank), which were subsequently accepted and paid out by the bank. The court ruled in favor of Lawrence County Bank stating that it is not within a bank's duty or responsibility to verify every signature on each check they receive; rather this obligation lies with their customers who present these checks for payment. Therefore, unless there is evidence showing negligence or bad faith on part of the banking institution in handling such transactions, banks cannot be held accountable for unknowingly facilitating fraud through acceptance and payment of counterfeit checks.

In the dissenting opinion for Moses v. Lawrence County Bank, it was argued that the majority's decision failed to properly consider and apply relevant legal principles. The dissenting justices believed that the bank had a legitimate claim to recover its losses from Moses, who they viewed as having acted in bad faith by knowingly accepting counterfeit money. They contended that this case should have been treated like any other involving fraud or deceit, with the wrongdoer being held accountable for their actions. Furthermore, they disagreed with the majority's interpretation of Mississippi law regarding liability for receiving counterfeit currency, arguing instead that such laws were intended to protect innocent parties rather than those acting dishonestly or negligently. In essence, their view was one of strict liability: if someone accepts counterfeit money and passes it on causing harm to another party then they should be held responsible regardless of whether they knew it was fake at first.