Walter v. National City Bank

National Bank (defendant) loaned Ritzer money under a 90-day promissory note executed after Ritzer's own balance sheet already showed insolvency, and when a judgment creditor, Walter (plaintiff), tried to garnish Ritzer's account before the note matured, the bank instead used its internal rules -- purporting to allow setoff against any indebtedness regardless of maturity -- to seize the funds for itself. The trial court and court of appeals ruled for Walter, and the bank appealed.