State Security Check Cashing, Inc. v. American General Financial Services (DE)
Maryland Court of Appeals
972 A.2d 882 (2009)
A man (imposter) purporting to be Ronald Wilder called American General Financial Services, Inc. (AG) (defendant) to procure a $20,000 loan. The imposter presented two years’ worth of personal tax returns as part of the loan-application process. Thereafter, the imposter went to AG’s office and provided, as identification, a license with his own photo and Ronald Wilder’s identifying information. AG then issued an $18,000 loan check without calling the personal references provided by the imposter. The imposter subsequently appeared at State Security Check Cashing, Inc. (State Security) (plaintiff) to cash the check, offering the same license previously presented to AG. The State Security employee confirmed with a State Security compliance officer that the employee had taken all actions required to properly verify the check. Upon supervisory approval, State Security cashed the check. After receiving notification of the fraud from the real Ronald Wilder, AG placed a stop-payment order on the check. State Security brought suit against AG, arguing that AG was liable for the loss because State Security was a holder in due course. The trial court found in AG’s favor, determining that State Security did not exercise ordinary care under Uniform Commercial Code (UCC) § 3-404 when paying the check, and that this failure played a significant role in the loss. State Security appealed. The intermediate circuit court affirmed. The Maryland Court of Appeals granted State Security’s petition for writ of certiorari.
Rule of Law
Holding and Reasoning (Harrell, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.