The plaintiff in Gemstone Foods, L.L.C. v. JPMorgan Chase Bank, N.A, was a Mississippi food processor with no banking relationship with Chase. Nevertheless, it alleged that Chase failed to adequately vet certain account-holder and thus facilitate the misdirection of $187,000 in wire transfers into sham accounts. The Fifth Circuit held that Chase owed no duty of care to a non-customer under Mississippi law. The court was not persuaded that the “sham account” issue created enough of a factual difference from earlier precedent to allow departure from it under the rule of orderliness, or to require certification to the Mississippi Supreme Court. No. 26-60049 (May 29, 2026).