In Wylie v. Northampton Bank, the Supreme Court of the United States was asked to decide whether a bank could be held liable for the wrongful acts of its officers. The case arose when the Northampton Bank of Massachusetts refused to honor a check drawn on it by one of its officers, William Wylie. Wylie had been authorized to draw checks on the bank, but the bank refused to honor the check because it had not been signed by the president of the bank. The Supreme Court held that the bank was liable for the wrongful acts of its officers. The Court reasoned that the bank had a duty to exercise reasonable care in the selection and supervision of its officers, and that it had failed to do so in this case. The Court also held that the bank was liable for the wrongful acts of its officers even if the bank had not authorized the act in question. The Court's decision in Wylie v. Northampton Bank established that banks can be held liable for the wrongful acts of their officers, even if the bank had not authorized the act in question. This decision has been cited in numerous subsequent cases involving the liability of banks for the wrongful acts of their officers.

Justice Field delivered the dissenting opinion in Wylie v. Northampton Bank, arguing that the majority's decision was contrary to established law and precedent. He argued that a bank is not liable for damages resulting from its negligence when it pays out money on forged checks or drafts unless there is proof of actual knowledge of fraud by an officer or agent of the bank. The Court had previously held in similar cases that banks are only liable if they have been negligent in failing to discover such frauds, but here Justice Field argued that this principle should be extended further so as to include situations where a bank has failed to exercise reasonable care and diligence with respect to payment made upon forged instruments. Furthermore, he contended that even if it were assumed without deciding whether a duty exists under these circumstances, then at least some degree of fault must be shown before liability can attach; otherwise any person who presents a check knowing it was forged would escape responsibility for their actions simply because no one else could prove they knew about the fraud beforehand.