Arthur Woods died holding an annuity payable on his death to his wife, Dorothy. In payment of the annuity, a checking account for $24,900 was established in Dorothy Woods’s name. The bank sent the checkbook and account statements to Woods’s attorney, who had requested that the account be established for Woods. Six unauthorized checks bearing Dorothy Woods’s forged signature were drawn on her checking account.

Woods discovered the forgeries a year later when she received the checkbook and bank statements from her attorney. She notified the bank of the forgeries 15 months after they had been written. Was the bank responsible for paying the forged checks? Why or why not? Woods v. MONY Legacy Life Insurance Company, 84 N.Y.2d 290 (NY).