1- [Melvin] Schultz died on July 5, 2005, at the age of 81.
* * * Before he died * * * he developed some sort of relationship with [Robin] Holbrook, who had moved into Schultz’s home.
Holbrook was apparently acting as Schultz’s caregiver, but Petitioner [Stephen Schultz, Melvin Schultz’s son and personal representative]
alleges that Holbrook also took advantage of Schultz by having her name added to Schultz’s account with the Bank [of America, N.A.].
Petitioner has advanced two theories as to how this occurred, one in which Holbrook coerced Schultz into adding her name to his account and another in which Holbrook had her name added through forgery.
There is no dispute that Holbrook’s name was in fact added to Schultz’s account and that she made withdrawals from the account.
Petitioner fi led suit against the Bank, alleging that the Bank negligently handled Schultz’s account * * * . At trial, * * * a handwriting expert examined several of Schultz’s known signatures and the signature card that was used to add Holbrook’s name to Schultz’s bank account. He opined that the signature purporting to be Schultz’s on the signature card was not the signature that Schultz used in the normal course of business. He also testified that several checks drawn on Schultz’s account appeared to have been forged with Schultz’s signature.
Petitioner * * * testified to the deterioration in Schultz’s health, and * * * that the signatures on some checks drawn from Schultz’s bank account were not authentic. He also explained that there had been activity on Schultz’s ATM account after Schultz met Holbrook, even though Schultz never used an ATM.
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* * * The trial court denied the Bank’s motion [for summary judgment], concluding that expert testimony was unnecessary to establish the standard of care on the facts of this case, [and] that there was suffi cient evidence to submit the negligence claim to the jury * * * .
[At trial, the jury found in Schultz’s favor. The bank appealed, and the Court of Special Appeals (an intermediate appellate court)
reversed the trial court’s judgment.
Schultz then appealed to Maryland’s highest state court, the Court of Appeals.]
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In a negligence case, there are four elements that the plaintiff must prove to prevail: “a duty owed to him [or her] (or to a class of which he [or she] is a part), a breach of that duty, a legally cognizable causal relationship between the breach of duty and the harm suffered, and damages.” In regard to the duty a bank owes to its customers when disbursing the customers’ funds, banks are not to be held strictly liable for every wrongful disbursement. Instead, our case law and the comments to the Maryland Uniform Commercial Code (“Commercial Code”) establish that a duty of “ordinary care” applies.
The Commercial Code defi nes “ordinary care” as the “1) observance of reasonable commercial standards, 2)
which prevail in the area in which the person is located, 3) with respect to the business in which the person is engaged.” A bank customer may bring a negligence suit against a bank for a violation of this duty of ordinary care. [Emphasis added.]
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In this case, Petitioner’s negligence claim is based on his allegation that the Bank failed to satisfy its duty of ordinary care in regard to its handling of Schultz’s checking account. Specifically at issue in this appeal is Petitioner’s claim that the Bank did not satisfy that duty when it “fail[ed] to properly add Holbrook to the account and verify her and [Schultz’s] identities.”
The Bank argues that expert testimony was necessary to establish the Bank’s standard of care, while Petitioner contends that * * * no expert testimony was necessary to explain the Bank’s standard of care to the jury. We disagree with Petitioner’s contention * * * .
To explain [the process of adding names to bank accounts], a plaintiff must produce expert testimony from someone familiar with the process from a bank’s perspective.
Petitioner also failed to provide evidence of the reasonable commercial banking standards that prevail specifi cally in the relevant geographical area of the Bank, as required by the ordinary care standard.
Finally, banking practices are changing in the era of the Internet and other electronic banking practices.
Bank procedures may not be the same today as they were just a few years ago, which also means that an expert may be necessary to explain to the trier of fact [a judge or jury] what duty a bank owes to a customer.
* * * *
When negligence is alleged against a bank, * * * expert testimony is ordinarily necessary to establish the applicable standard of care. Such testimony is not necessary when the bank’s alleged negligence, if proven, so obviously deviated from the applicable standard of care that the trier of fact could appreciate the deviation without an expert’s assistance.
The alleged negligence in this case, however, involved internal banking procedures that the trier of fact could not be expected to appreciate.
Petitioner should have provided expert testimony to explain to the jury what banks ordinarily do to protect their customers from imposters when adding a name to the customer’s account, so that the jury could then decide whether the Bank had acted in accordance with the duty of ordinary care. Instead, Petitioner provided no testimony on this issue at all. Without expert testimony to explain the duty of ordinary care, the jury could not know whether to hold the Bank accountable for failing to protect its customer’s account. Petitioner therefore failed to provide any competent evidence of the duty owed to him, a necessary element of a negligence claim, and the trial court should not have submitted this claim to the jury. We agree with the Court of Special Appeals that the trial court should have granted the Bank’s motion for judgment.
Judgment of the court of special appeals affirmed.

Questions:-

1. “Expert testimony should not be required to inform jurors of what a reasonable standard of care should be in commonplace banking transactions.” Do you agree with this statement? Why or why not?

2. Suppose that both Schultz and the bank had been found negligent in the addition of Holbrook’s name to Schultz’s account. In this situation, which party would be liable for any damages resulting from the negligence? Explain.