Thompson Maple Products, Inc. v. Citizens National Bank

Thompson Maple Products, Inc. (Thompson) (plaintiff) manufactured bowling pin blanks from maple logs. Thompson’s business model was to purchase logs from timber owners in the surrounding area. The logs would be transported to Thompson’s mill by a few local truckers. When the logs arrived, a Thompson employee would evaluate the quantity and grade of the logs and document that information, along with the owner of the logs, on a scaling slip. Pads of the scaling slips were left in areas readily accessible to any of the truckers. The slip was filled out in duplicate. The procedure was for the Thompson employee who filled out the slip to give the copy to the trucker and deliver the original directly to the Thompson bookkeeper. This was not followed in practice. Rather, the Thompson employee would usually give both copies to the trucker, who would take them to the office. Employees in the Thompson office would then issue checks to the owners of the logs. Thompson employees regularly entrusted these checks to the truckers to be delivered to the owners of the logs. Emery Albers was one of the truckers who transported logs to Thompson. Albers obtained blank slips and forged them to show deliveries of logs that did not occur, using names of local timber owners as suppliers. Albers then obtained checks issued to those timber owners and forged the owners’ signatures. Albers either cashed the checks or deposited them into his personal account. The forgeries were eventually discovered, and Thompson sued its bank, Citizens National Bank (the Bank) (defendant), for paying checks with forged endorsements. The trial court ruled in favor of the Bank, and Thompson appealed to the Superior Court of Pennsylvania.