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Harrington v. Taylor

Supreme Court of North Carolina
225 N.C. 690, 36 S.E. 2d 227 (1945)
ELI5:

Rule of Law:

A promise to pay for a benefit that was previously and voluntarily conferred is unenforceable for lack of consideration, as a past humanitarian act does not constitute a valid legal basis for a subsequent promise.


Facts:

  • The defendant assaulted his wife, who then sought refuge in the plaintiff's home.
  • The next day, the defendant entered the plaintiff's home and began to assault his wife again.
  • The defendant's wife retaliated by knocking the defendant to the floor with an axe.
  • As the wife was about to strike the defendant again while he was on the floor, the plaintiff intervened.
  • The plaintiff caught the descending axe, which severely mutilated her hand but saved the defendant's life.
  • Sometime after this event, the defendant orally promised to pay the plaintiff for her damages.
  • The defendant made a small payment to the plaintiff but then ceased making any further payments.

Procedural Posture:

  • The plaintiff filed a complaint against the defendant in a trial court to recover on his oral promise.
  • The defendant demurred to the complaint, arguing it failed to state a valid cause of action because the promise was not supported by consideration.
  • The trial court sustained the defendant's demurrer, dismissing the plaintiff's case.
  • The plaintiff appealed the trial court's judgment to the higher court.

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Issue:

Does a voluntary, humanitarian act, performed without any expectation of payment, constitute sufficient consideration to make a subsequent promise to pay for injuries sustained during the act legally enforceable?


Opinions:

Majority - Per Curiam

No, a voluntary, humanitarian act does not constitute sufficient consideration to make a subsequent promise legally enforceable. The court reasoned that while the defendant has a strong moral obligation and should be impelled by gratitude to compensate the plaintiff, a voluntary, humanitarian act is not the type of bargained-for exchange that contract law recognizes as valid consideration. The plaintiff's act of saving the defendant was performed before any promise was made and not in exchange for that promise. Therefore, the defendant's subsequent promise is merely a gratuitous one and cannot be enforced at law.



Analysis:

This case serves as a stark example of the traditional common law doctrine that 'past consideration is no consideration.' The court strictly separates moral obligations from legal duties, holding that a sense of gratitude for a past benefit is insufficient to form the basis of a binding contract. This ruling highlights the potential for harsh outcomes under a rigid application of the consideration doctrine, as it leaves a severely injured rescuer without a legal remedy despite the promisor's initial intent to compensate her. The case contrasts with the more modern 'material benefit rule,' which some jurisdictions have adopted to enforce such promises to prevent injustice.

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