Rhode Island

Angel v. Murray in Rhode Island Law

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

State Approach

Rhode Island generally follows the principles of modification in contract law as established in Angel v. Murray, recognizing the enforceability of agreements that arise from the necessary modification of a contract when unforeseen circumstances occur. The state emphasizes the need for consideration, but the threshold for what constitutes sufficient consideration can sometimes be less stringent than in other jurisdictions.

State Rule
In Rhode Island, a contract modification may be enforceable without new consideration if it is fair and equitable, given circumstances that were unforeseen at the time of the original agreement.
Significant State Cases

Gorman v. Hiers

This case held that a modification of a contract must be supported by either new consideration or must be based on unforeseen circumstances that make the original terms inequitable.

Pellegrino v. Sweeney

The court held that a modification made under conditions of mutual assent and in the interest of fairness can be enforceable despite the lack of new consideration.

United States v. Sweeney

This decision confirmed the application of fair dealing principles from Angel v. Murray, emphasizing fairness in contract modifications.

Comparison to Federal Law

Rhode Island's approach aligns with the Restatement (Second) of Contracts, which provides that a modification is enforceable if it is fair and equitable. However, federal law, particularly under UCC § 2-209, tends to be more rigid regarding enforceability unless new consideration is provided, reinforcing a stricter standard for modifications.

Bar Exam Note

Angel v. Murray illustrates key concepts in contract modification, and understanding these principles is essential for the Rhode Island bar exam, particularly in contract law questions regarding enforceability and consideration.

Practice Pointers
  • Always evaluate if any unforeseen circumstances justify a contract modification under Rhode Island law.
  • Assess whether the terms of the modification can be deemed fair and equitable in light of the original context of the contract.
  • Be familiar with significant case law in Rhode Island that interprets contract modifications and consider how these principles could be applied in hypothetical scenarios.

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