The U.S. Supreme Court case Troy Bank v. G.A. Whitehead & Company (Incorporated) in 1911 revolved around a dispute over the payment of checks between two banks, specifically whether or not one bank was liable for paying on forged endorsements. The plaintiff, Troy Bank, had paid out on several checks that were presented to it by the defendant, G.A Whitehead & Co., which later turned out to have been endorsed with forged signatures. When this came to light, Troy Bank sued Whitehead & Co., arguing that they should be reimbursed for their losses because they had relied upon and trusted the defendant's endorsement of these fraudulent checks. The court ruled in favor of the defendant stating that when an innocent holder presents a check for payment bearing a forged endorsement and receives payment thereon from the drawee bank without any negligence on his part contributing thereto before maturity thereof is entitled under Negotiable Instruments Law § 62(3), he is deemed prima facie to be a holder in due course until contrary is proven.

In the dissenting opinion for Troy Bank v. G.A. Whitehead & Company, it was argued that the majority's decision failed to properly consider and apply established legal principles regarding negotiable instruments law. The dissent took issue with the majority's interpretation of what constitutes a holder in due course, arguing that under existing laws and precedents, Troy Bank should not be considered as such because they had knowledge of an infirmity in the instrument or defect in the title of the person negotiating it at the time it was negotiated to them. Furthermore, they disagreed with how much weight was given by majority to certain facts presented during trial which led them to their conclusion about bank’s status as a holder in due course.