First Safety Fund National Bank v. Friel

On two separate occasions, Janet M. Friel, the defendant, signed promissory notes on behalf of New England Office Products Co., Inc., of which she was president. On each note Friel signed twice: once, directly under the typed name of the corporate borrower, she wrote “Janet M. Friel, President”; upon the line below that signature she wrote, without qualification, “Janet M. Friel.” The question presented is whether the second signatures rendered Friel personally liable on the notes. We conclude that they did and reverse the court below.

The appeal is from a divided opinion (Dohoney, J.,…