Leeds v. Chase Manhattan Bank, N.A.
Appellate Division of the Superior Court of New Jersey
752 A.2d 332 (2000)
Attorney Egnasko altered a settlement check payable to his clients, the Leedses (plaintiffs), by typing his own name above the payee line, then deposited it into his attorney trust account at Chase (defendant), which presented it to drawee Summit (defendant), and Summit honored it. Egnasko separately used funds obtained through a similar scheme against another client to issue the Leedses a replacement check from a different bank, which they cashed. The Leedses sued Chase as depository bank and Summit as drawee/payor bank for strict liability conversion on the original altered check; the lower court granted both banks summary judgment, and the Leedses appealed.
Whether a depository bank is strictly liable for conversion on a forged or stolen instrument.