Triffin v. Dillabough

Facts

On an unknown date, a batch of blank American Express money orders were stolen while being shipped to its agents for sale to the public. These money orders contained the pre-printed signature of the then Chairman of American Express but were blank as to amount, sender, payee and date. On December 11, 1990, Dillabough presented two American Express money orders for payment a check cashing operation in Philadelphia. The owner of this check cashing operation was unaware the money orders had been stolen until they were returned him with the stamp “reported lost or stolen. do not redeposit.” American Express had noted these money orders as stolen on its “fraud log” and refused to pay the face amounts of the money orders. The owner of the check cashing operation then sold the money orders to Triffin, a commercial discounter, who received all right, title and interest in the money orders. Triffin filed separate complaints against Dillabough and American Express to recover the value of the money orders.