Pennsylvania

Angel v. Murray in Pennsylvania Law

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

State Approach

In Pennsylvania, the principle of modifying contracts due to unanticipated circumstances follows the doctrine of consideration. Courts evaluate modifications carefully, often requiring additional consideration to support changes to contracts, aligning with the objective theory of contracts.

State Rule
In Pennsylvania, the modification of a contractual agreement requires mutual assent, often evidenced by new consideration, except in cases where the agreement falls under the UCC which permits modifications without additional consideration.
Significant State Cases

Baker v. Family Credit Counseling Corp.

The court held that contract modifications must be supported by new consideration unless a statutory exception applies.

Wood v. Lucy, Lady Duff-Gordon

The Pennsylvania Supreme Court reaffirmed that a contract must have mutual obligations; lack of consideration invalidates modifications in certain circumstances.

Baldwin v. City of Philadelphia

Modification of contracts requires clear demonstration of agreement to altered terms to be enforceable.

Comparison to Federal Law

Pennsylvania law places greater emphasis on the requirement of consideration for contract modifications compared to the federal approach, which may more regularly accept modifications based on equitable principles even in the absence of additional consideration. This reflects a more rigid interpretation of contract modification under state law.

Bar Exam Note

The principle of strict consideration in contract modifications is relevant in the Pennsylvania bar exam, particularly in the context of contract formation and enforceability issues.

Practice Pointers
  • Always identify if additional consideration is provided for the modification of contracts to ensure enforceability.
  • Consider the applicability of the UCC if the contract involves goods, as this may change the requirements for modification.
  • Review relevant case law in Pennsylvania to understand nuances in contract interpretation and modification.

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