New York Court of Appeals

The Standard Steam Specialty Company, Appellant v. the Corn Exchange Bank, Respondent

April 24, 1917220 N.Y. 478

Summary

The Court reversed the Appellate Division, holding that the stenographer's indorsements were forgeries under Negotiable Instruments Law § 42, so no title passed to the bank and the bank is liable to the plaintiff for the proceeds. The decision rests on the principle that an agent authorized only to make a restrictive indorsement cannot make a general indorsement.