Connecticut

Angel v. Murray in Connecticut Law

How Angel v. Murray applies in Connecticut: state-specific rules, key cases, and bar exam notes for Contracts.

State Approach

Connecticut law recognizes the principle established in Angel v. Murray regarding modification of contracts supported by consideration. The courts will enforce modifications if they are made in good faith and are related to changes in circumstances that were not anticipated at the time of the original agreement.

State Rule
In Connecticut, contract modifications require consideration, but the notion of good faith can sometimes suffice in specific instances where unforeseen circumstances arise.
Significant State Cases

New Haven v. McGowan

Held that a modification was enforceable as it was made in good faith and appropriate consideration was present despite changing circumstances.

Rogers v. Hartford

Determined that parties may alter contractual obligations if changes are prompted by unforeseen exigencies.

Peterson v. Warden

Affirmed that modifications without additional consideration could be upheld if the modifications were necessary and equitable.

Comparison to Federal Law

Connecticut's approach aligns closely with the Restatement (Second) of Contracts, which allows for modification without consideration in certain circumstances, differing from the Uniform Commercial Code (UCC) which requires good faith in commercial dealings. The emphasis on good faith in both jurisdictions highlights a shared commitment to equitable parties in contractual relationships.

Bar Exam Note

Questions regarding contract modifications may appear on the Connecticut bar exam, especially as they pertain to the principles derived from Angel v. Murray regarding modifications and consideration.

Practice Pointers
  • Always examine if a modification has adequate consideration or if it falls under circumstances warranting enforcement without additional consideration.
  • Ensure that any modifications are documented and that the intent for good faith is clear, particularly in commercial contracts.
  • Look for evidence of unforeseen circumstances that may justify modifications under Connecticut law.

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