Citizens Bank v. Maryland Industrial Finishing Co.

I agree that what is important in this case is “whether [the appellee’s agent] had authority to indorse the way she did, not whether she had authority to deposit the way she did.” Majority Op. at 460. Reasoning that' “the validity of an indorsement does not depend on the agent’s subjective motivation at the time of the indorsement,” Majority Op. at 12, the majority correctly observes:

It defies reason to allow an event that occurs after the indorsement to affect the validity of the indorsement. An indorsement is either valid or invalid at the time it is made; if, at that time, the agent has…