“If the question were put to the average layman whether the holder of a check...had any effective rights against the drawee bank, it is believed that the almost universal response would be to the effect that of course the holder may insist upon payment by the bank, if there are funds on deposit to cover the amount. And if the same question were propounded to the average lawyer, the reply generally would be--at least if the lawyer had in mind the provisions of the Uniform Negotiable Instruments Law--that the holder had no rights against the bank. It is the purpose of this paper to inquire into the accuracy of these two views.”
Aigler, Ralph W. "Rights of Holder of Bill of Exchange against the Drawee." Harv. L. Rev. 38, no. 7 (1925): 857–86.