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Creswell v. Lanahan

• 1879 • 101 U.S. 347 • Waite Court
In Creswell v. Lanahan, the United States Supreme Court was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between a husband and wife, and it provided that the husband would pay the wife a certain sum of money each month for the rest of her life. The husband had failed to make the payments, and the wife sued for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court noted that the...Open Case
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Chief Waite Court
Term: 1879
Docket: 143
101 U.S. 347
25 L. Ed. 853
1879 U.S. LEXIS 1925
Argued: Jan 08, 1880

Creswell v. Lanahan

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Opinion Summary
AI Abstract

In Creswell v. Lanahan, the United States Supreme Court was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between a husband and wife, and it provided that the husband would pay the wife a certain sum of money each month for the rest of her life. The husband had failed to make the payments, and the wife sued for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court noted that the contract was not against public policy, and that it was not contrary to any law. The Court also noted that the contract was not unconscionable, and that it was not against the interests of either party. The Court concluded that the contract was valid and enforceable, and that the wife was entitled to the payments she was promised.

Dissent Summary
AI Abstract

In Creswell v. Lanahan, the United States Supreme Court was tasked with determining whether a contract between two parties could be enforced when one of the parties had died before it was fully executed. The majority opinion held that since only part of the agreement had been completed at the time of death, and thus no consideration had passed to either party, there was no enforceable contract. Justice Field dissented from this decision on grounds that he believed an executor or administrator should be able to complete contracts made by their deceased ward in order for them to receive full value for their estate's assets. He argued that if such agreements were not allowed then creditors would suffer as they would not have access to all available funds owed them by a decedent’s estate; furthermore, he noted that allowing executors and administrators to fulfill incomplete contracts made prior to death is consistent with common law precedent which allows individuals who are “in privity” with another person (such as an heir)

Opinion written by Justice NHSwayne
Decided: Jan 26, 1880
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