Suburban Trust Co. v. Waller
Maryland Court of Special Appeals
44 Md. App. 335, 408 A.2d 758 (1979)

- Written by Miller Jozwiak, JD
Facts
Maurice Waller (plaintiff) had an account at the Suburban Trust Company (bank) (defendant). Waller attempted to cash a check at the bank. A teller declined to cash the check due to Waller having insufficient funds. So Waller went to the United States Treasury Department and cashed the check there. Waller then returned to the bank to deposit the money. When Waller did so, the bills had sequential numbers, which raised the teller’s suspicions. The teller reported the matter to a security official, who investigated. The security official called the Federal Bureau of Investigation (FBI) to see whether the sequential numbers were on a watchlist; the FBI officials said they were not. Unsatisfied, the security official then called local law enforcement, who reported that a recent residential robbery had occurred. This led to Waller’s arrest and charge for that robbery, although the charges were later dropped. Waller sued the bank for (among other things) breaching an implied condition of the relationship, namely, the duty of confidentiality. The matter went to trial, and Waller won. The bank appealed, claiming that the trial court erred in failing to rule as a matter of law that the limited disclosure was reasonable.
Rule of Law
Issue
Holding and Reasoning (Gilbert, C.J.)
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