Plaintiff's agent signed a check in blank, and placed it in a safe. A thief broke into the safe, removed the check and other papers, inserted "Cash'' as the payee and $486.50 as the amount, and was paid by the drawee bank. In an action against the bank for charging plaintiff's account with this item, the court held that as between the parties, because the bank was negligent in paying the check without sufficient identification, it must bear the loss. Joseph Heimberg, Inc. v. Lincoln Nat. Bank, (N. J. L. 1934) 172 Atl. 528.
BANKS AND BANKING-LIABILITY ON PAYMENT OF INCOMPLETE CHECK,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol33/iss3/9