In Cohen v.Disner the court found that Disner was not liable on the check because he had no enforceable obligation to pay, the check was drawn by him in a representative capacity, and the holder had notice that Disner's signature was in the capacity of an agent.

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In Cohen v. Disner, the court ruled that Disner was not personally liable because he signed the check as an agent, and the holder was aware of his representative capacity, thus he had no personal obligation to pay.

In Cohen V