On March 5, 2013, Geoff Millsom obtained the dismissal of a case against RBS Citizens, N.A. in the United States District for the District of Massachusetts that had been brought by a law firm whose payroll company maintained multiple accounts at Citizens Bank. The law firm alleged that Citizens was negligent and breached its fiduciary duty, certain contracts and violated Mass Gen laws ch. 93A by failing to ensure that its payroll company used the accounts to send its federal tax payments to the Internal Revenue Service. In support of its claims, the plaintiff relied on the New York case of Lerner v. Fleet Bank, N.A., which held that in certain circumstances a bank may have certain duties to non-customers. Judge Rya Zobel rejected plaintiff’s argument and held that it had not alleged sufficient facts to state a claim against Citizens under either Massachusetts or Rhode Island law. The decision is reported at Bennkopf Goodman v. Hebert et al., No. 11-cv-11495-RWZ (March 5, 2013, D. Mass).