The case of People's National Bank v. Marye in 1903 revolved around the issue of whether a bank could be held liable for accepting deposits from an executor who was misappropriating funds from an estate. The Supreme Court ruled that the bank had no duty to investigate the source of deposited funds and thus, could not be held accountable unless it was proven that they were aware or should have been aware that the money being deposited was being mishandled by its customer, in this case - an executor. This ruling established a precedent regarding banks' liability when dealing with potentially fraudulent transactions conducted by their customers.

In the dissenting opinion for People's National Bank v. Marye, Justice Harlan disagreed with the majority's interpretation of a Virginia statute that allowed banks to offset debts owed by depositors against their deposits in insolvency situations. He argued that this law was not intended to apply when a bank is under receivership or insolvent, but rather only when an individual depositor becomes insolvent. According to him, applying this law in cases of bank insolvency would unfairly prioritize certain creditors (those who are also depositors) over others and could potentially encourage fraudulent behavior by banks on the brink of failure. Furthermore, he contended that federal bankruptcy laws should take precedence over state statutes in such matters as they provide more equitable treatment for all creditors involved.