Supreme Court of Errors of Connecticut
19 A. 332 (Conn. 1889)
Sheldon Clark (Sheldon) was an old, single man and was dying of disease. In his older years, he often would stay in the house of his friend, Charles Clark (unrelated to Sheldon), and Charles’s wife (collectively, the Clarks). The Clarks looked after Sheldon, including but not limited to chores such as laundry and caring for him while he was sick. Sheldon consistently stated that he should pay the Clarks for their service. Eventually, Sheldon issued a promissory note to the Clarks in the amount of $700 “for value received.” Sheldon died soon after he issued the note. The superior court ruled that the promissory note was invalid due to lack of consideration. The Clarks appealed.
Rule of Law
Holding and Reasoning (Andrews, C.J.)
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