Miller Rubber Co. v. National Union Bank

4 Balt. C. Rep. 429
CourtBaltimore City Circuit Court
DecidedJanuary 6, 1926
StatusPublished

This text of 4 Balt. C. Rep. 429 (Miller Rubber Co. v. National Union Bank) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miller Rubber Co. v. National Union Bank, 4 Balt. C. Rep. 429 (Md. Super. Ct. 1926).

Opinion

SOLTER, J.

This is the same ease which went to the Court of Appeals upon a demurrer to the bill of complaint. It in[430]*430volved the liability of the bank for certain customers’ checks of the Miller Rubber Company, irregularly endorsed by its agents and deposited in the latter’s account in the Union Bank instead of the Miller Rubber Company’s account also in the Union Bank. The sufficiency of the bill was sustained by the Appellate Court. In this memorandum, as the dealings are between principal and agent, it may tend to keep the relationship always apparent by referring to “Factory” in place of complainant, “Branch” for Shuman and Robinson, except in some instances when reference is made to certain checks, and “Bank” as the defendant.

By the evidence in this case the factory has established the liability of the bank. The decision of the Court of Appeals deals with two questions raised by the bank as defenses; viz: lack of privity and the right to maintain this proceeding in an equity Court. The decision was adverse to the bank upon both points. The facts offered in eviidence by the factory in no way differ from those set forth in the bill of complaint. The factory established the liability of the bank by proof that it, the bank, collected from the drawee banks the proceeds of cheeks which should have been deposited in the factory’s account in the bank, but which by irregular endorsements were deposited instead to the credit of Shuman and Robinson, the proprietors of the branch. It further proved the arrangements under which the factory’s deposit account was opened with the bank, the knowledge it had of the factory’s signature, its knowledge of the relationship existing between the factory and the branch and alsq its knowledge that Shuman and Robinson had no authority to endorse checks drawn to the factory’s order for their individual account. After proof of the diverted checks and the other facts above stated, it rested its case.

The defense of the bank is that these diverted checks were subsequently made good by Shuman and Robinson. In the examination of the witness Graneecum, the auditor of the factory, its ledgers were offered in evidence and it appeared from them that these diverted checks had been given by factory customers in payment of certain specified invoices, and that the factory had credited .these customers with payments of the same invoices to the extent of $16,951.58 by later deposits in the factory’s bank account made by the branch. The bookkeeping arrangements of the factory and the branch are as follows: The factory and the branch kept full sets of 'books and the ledgers of both should show identical entries in the customers’ accounts. The customers’ debits were entered in the factory ledger through duplicate invoices sent daily by the branch and they received credits on the factory ledger through “Remittance advices,” also sent daily by the branch. The “Remittance advices” purported to show customers’ payments received by the branch and these were supported by a duplicate deposit slip purporting to show the deposits made in the bank of these customers’ payments. Usually there was also deposited in the factory’s bank account the amount of any cash sales made by the branch and these were also included in the “Remittance advices.” By this system the entries in the factory ledger and in the branch ledger upon customers’ account would be precisely the same. In the examination of the affairs of the branch after the discovery of the irregularities of Shuman and Robinson a large number of copies of deposit slips were discovered by the factory's auditor. Opposite the items on these deposit slips were notations showing the name of the customer whose check made up part of the deposit. It was clearly shown by these deposit slips and notations that the practice of the branch was to make deposits in the factory account in the bank of certain customers’ checks and send on remittance advices which would advise a credit upon a customers’ account which in point of fact had been made by him prior thereto, but whose check had been diverted. It might be stated in passing that the branch always kept its accounts with the customers with accuracy according to his actual purchases and the payments reported to the factory and relied upon certain symbols on the ledger to enable Shuman and Robinson to know how these accounts stood with the customer. Of course a comparison of the factory ledger with the branch ledger would not have shown the irregularities. It can be readily seen, that unless there was deposited in the bank by the branch money or checks which actually belonged to Shuman and Robinson the branch was merely accounting for a part of the money actually belonging [431]*431to the jaotory. The factory in acting upon the remittance advices sent in by the branch was in practically every instance making entries in the ledger which did not correspond with the payment actually made by its customers. It should be noted at this point: that the goods sold were at all times until sale the property of the factory and not the property of the branch. It should be further noted that the indebtedness created by the sale was an indebtedness from the customer to the factory and not to the branch; and further, when a customer’s check was received in payment for the goods represented by invoices, this check was always the property of the factory and not of the branch. The branch was merely the agency through which it dealt with its customers. As between the branch and the factory, the latter was not bound by any remittance advices which did not truthfully portray the customer’s dealings. It was entirely proper for the factory when the true state of facts became known to recast its books in accordance with what any particular customer had actually bought and what he had in fact did, so far as it was possible, after knowledge of the defalcations. It first took steps to secure from the customers as many as possible of the checks they had sent in to the branch and those which had been diverted to the use of Shuman and Robinson by their irregularities thus became the items of this particular suit.

By the fraudulent practices of stealing one check and using another winch also belong to the factory to conceal the theft, B’s check was made to pay A’s bill on the books of the factory ; but it is obvious that as between tlie factory and the branch, A’s bill nevertheless was unpaid and the whole structure of fraudulent accounting had to fall and be restored to a state of truth. I therefore hold that merely because the customer’s account has become credited through the fraudulent remittance advices they cannot he allowed as credits against the diverted cheeks. The basic rule obviously underlying the condition of affairs is that the only credits which can be allowed against diverted checks would be funds which were absolutely the property of Shuman and Robinson and which can in some way be shown to have been paid to the factory. Nor can it be assumed that these ledger credits show even prima facie that Shuman and Robinson made restitution of the diverted checks through the medium of remittance advices and supporting deposits in the factory bank account, as the basis of this credit was always the factory’s bank account it must be assumed as a starting point that the money placed there by the branch was customer’s money and not money of Shuman and Robinson. In other words, the remittance advices and the deposit of funds by the branch to support such advices can, standing alone, raise no presumption of restitution.

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Bluebook (online)
4 Balt. C. Rep. 429, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-rubber-co-v-national-union-bank-mdcirctctbalt-1926.