California
How Angel v. Murray applies in California: state-specific rules, key cases, and bar exam notes for Contracts.
In California, the principles from Angel v. Murray emphasize that modifications to contracts require consideration to be enforceable. However, under certain circumstances, the doctrine of promissory estoppel may apply to enforce non-consensual modifications when one party relies on the promise of another.
Under California law, a modification of an existing contract typically needs new consideration to be enforceable, except in cases where promissory estoppel can prevent unjust enrichment.
The court held that an oral modification to a written agreement was enforceable due to the reliance of the party seeking enforcement on the modified agreement.
This case reinforced the requirement of consideration for contract modifications while also recognizing exceptions based on reliance.