A federal District Court in Florida has held that a bank has a duty to avoid negligence in opening a bogus bank account for a nonprofit organization. When confronted with a claim that the organization's CFO had opened the account without authority and had withdrawn $360,000 for his personal benefit, the bank said it had no duty to the nonprofit because it was not a customer. Journeys Academy had an account with PNC Bank. Its CFO opened a new account with Liberty Bancshares on the basis of a false corporate resolution. When the situation became apparent, Journeys sued Liberty for negligence. Liberty filed a motion to dismiss on the ground that it had no duty to Journeys because Journeys was...