Virginia National Bank v. Holt
Supreme Court of Virginia
219 S.E.2d 881 (1975)
Virginia National Bank (VNB) (plaintiff) sued Gustava Holt and her husband (defendants) on a promissory note bearing what appeared to be both their signatures; a default judgment was entered against Holt's husband, but Holt denied signing the note. At trial, VNB's witnesses testified the signature was Holt's, while Holt's only supporting evidence was VNB's own interrogatory answers stating VNB knew of no one who saw Holt sign the note and didn't know whether she'd authorized her husband to sign for her. The jury found for Holt, and the trial court denied VNB's motion to set aside the verdict, holding the signature's validity was properly a jury question; VNB sought review.
Whether a signature on an instrument is presumed to be genuine or authorized unless sufficient evidence is introduced to support a finding that the signature is forged or unauthorized.