Fordham Urban Law Journal Volume 14 | Number 1 Article 3 1986 Automatic Teller Machine Robberies: Theories of Liability Joan Miles Fordham University School of Law Follow this and additional works at: https://ir.lawnet.fordham.edu/ulj Part of the Torts Commons Recommended Citation Joan Miles, Automatic Teller Machine Robberies: Theories of Liability, 14 Fordham Urb. L.J. 171 (1986). Available at: https://ir.lawnet.fordham.edu/ulj/vol14/iss1/3 This Article is brought to you for free and open access by FLASH: The orF dham Law Archive of Scholarship and History. It has been accepted for inclusion in Fordham Urban Law Journal by an authorized editor of FLASH: The orF dham Law Archive of Scholarship and History. For more information, please contact
[email protected]. AUTOMATED TELLER MACHINE ROBBERIES: THEORIES OF LIABILITY I. Introduction The emergence of the electronic banking age,' while bringing considerable convenience to the consumer and savings to the banking industry,2 has created complex legal issues and problems.' One me- dium of electronic fund transfers (EFT),4 the twenty-four hour au- tomated teller machine (ATM), has gained nationwide acceptance5 1. See Schroeder, Developments in Consumer Electronic Fund Transfers, 69 FED. RESERVE BULL. 395, 395-97 (1983) [hereinafter cited as Developments]; Naar & Stein, EFTS: The Computer Revolution in Electronic Banking, 5 RUTGERS J. COMPUTERS AND L. 429-431 (1976). 2. A report by the Federal Reserve Board has described the savings to financial institutions which have adopted electronic banking services. See Developments, supra note 1. For example, in 1981, the average cost of processing a check deposited by mail was 59 cents, while the average cost for preauthorized electronic deposit was a mere 7 cents.