Thompson Maple Products, Inc. v. Citizens National Bank
Superior Court of Pennsylvania
234 A.2d 32 (1967)
Thompson Maple Products, Inc. (plaintiff) bought logs from timber owners, using employee-completed scaling slips and issuing checks to the owners; company procedure called for keeping copies separate and delivering checks directly, but in practice both slip copies and completed checks were regularly entrusted to the delivering truckers themselves, and Thompson kept no accurate inventory to verify payments against actual deliveries. Trucker Emery Albers forged blank slips to show fictitious deliveries under real timber owners' names, then forged those owners' signatures on the resulting checks and cashed or deposited them; once discovered, Thompson sued its bank, Citizens National Bank (defendant), for paying checks bearing forged endorsements. The trial court ruled for the Bank, and Thompson appealed.
Whether, under the Uniform Commercial Code, a person who substantially contributes to the making of an unauthorized signature on an instrument through negligence is precluded from asserting the lack of authority against the bank who paid the instrument in good faith in accordance with reasonable commercial standards.