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State Security Check Cashing, Inc. v. American General Financial Services, Inc.

Court of Appeals of Maryland
972 A.2d 882 (2009)


An imposter posing as Ronald Wilder obtained a loan from American General Financial Services, Inc. (American General) (defendant). American General issued to the imposter a loan check made out to Wilder. The imposter presented the check to State Security Check Cashing, Inc. (State Security) (plaintiff) for cashing. State Security reviewed a driver’s license the imposter presented—the same license the imposter had presented to American General—as well as the loan documents that American General had created. In addition, State Security compared the check to other checks drawn by American General that State Security had cashed previously. Finding the paperwork to be in order, State Security cashed the check. The next day, before State Security had presented the check to the bank for payment, Wilder informed American General that an impostor had applied for a loan using his name. American General placed a stop-payment order on the check. State Security brought suit in the District Court of Maryland against American General for the value of the check. The district court found that State Security did not exercise ordinary care in the cashing of the check and ruled in favor of American General. The Circuit Court for Baltimore County affirmed. The Court of Appeals of Maryland issued a writ of certiorari.

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