Maryland
How Angel v. Murray applies in Maryland: state-specific rules, key cases, and bar exam notes for Contracts.
In Maryland, the principles from Angel v. Murray are largely followed through the enforceability of modifications and the consideration doctrine. However, Maryland emphasizes a stronger reliance on bilateral agreements and good faith in contract performance and modification.
In Maryland, a modification to a contract is enforceable if it is supported by mutual consent and consideration or if it meets the requirements of the Restatement (Second) of Contracts, particularly § 89 regarding modification without consideration.
The court held that a unilateral modification due to circumstances not considered at the time of the original contract was enforceable as long as it did not violate good faith obligations.
The court acknowledged that modifications to contracts must have consideration unless under strict legal or equitable circumstances.
In this case, the court reinforced that modifications must be made in good faith and that mere unilateral intentions are insufficient for enforceability.
Maryland's approach aligns closely with the federal standard established under the Restatement (Second) of Contracts, particularly concerning the necessity of consideration for contract modifications. However, Maryland places a stronger emphasis on mutual consent and the requirement of good faith in enforcing modifications.
Understanding the implications of Angel v. Murray is critical for the Maryland bar exam, particularly how consideration and good faith affect contract modifications and enforceability.