Earle v. Angell

157 Mass. 294, 32 N.E. 164 (1892).

Dawson, pp. 206-207


Facts: Dewitt promised her nephew, Earle, $500 in return for attending her funeral.  Earle did attend and sued her estate for the $500.  The jury found that a promise was given for a promise.


Issue: Was a promise given for a promise?


Rule: “[A] contract to pay money after one’s own death is valid.”


Analysis: The court says that there is no legal difficulty in enforcing the contract.


Conclusion: The court upheld the trial court’s verdict for the plaintiff.


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