Bank’s Duty to Honor Checks. Sheila Bartell was arrested and subject to various charges related to burglary, the possession for sale of methamphetamine, and other crimes. She pleaded guilty in a California state court to some charges in exchange for the dismissal of others and an agreement to reimburse the victims.

The victims included “Rita E.,” who reported that her checkbook had been stolen and her signature forged on three checks totaling $590. Wells Fargo Bank had “covered” the checks and credited her account, however, so the court ordered Bartell to pay the bank. Bartell appealed, arguing that the bank was not entitled to restitution. What principles apply when a person forges a drawer’s signature on a check? Is the bank entitled to recover from the defendant? Explain. [People v. Bartell, 170 Cal.

App.4th 1258, 88 Cal.Rptr.3d 844 (3 Dist. 2009)]