Hutchinson v. Penn State Investors Life Insurance

43 Pa. D. & C.2d 301, 1967 Pa. Dist. & Cnty. Dec. LEXIS 216
CourtPennsylvania Court of Common Pleas, Dauphin County
DecidedJuly 3, 1967
Docketno. 1005
StatusPublished

This text of 43 Pa. D. & C.2d 301 (Hutchinson v. Penn State Investors Life Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Dauphin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hutchinson v. Penn State Investors Life Insurance, 43 Pa. D. & C.2d 301, 1967 Pa. Dist. & Cnty. Dec. LEXIS 216 (Pa. Super. Ct. 1967).

Opinion

Bowman, J.,

In this motion for judgment n.o.v., defendant, Penn State Investors Life Insurance Company (Penn State) raises one contention which, if sound, would require entry of judgment in its favor notwithstanding a contrary jury verdict.1 The issue raised goes to the fundamental question of whether legal consideration was present to support a promise of Penn State to pay a certain sum of money to plaintiff, James H. Hutchinson.

Considering all of the evidence and reasonable inferences to be taken therefrom in a light most favorable to the verdict winner (Schreckengost v. Kraft, 415 Pa. 567 (1964)), the record discloses that [303]*303plaintiff property owner entered into a written lease agreement with Penn State for the latter’s use of office space in a commercial building for a term of five years beginning June 14, 1963, at a total rental of $17,475, to be paid in monthly installments of $290. In the latter part of 1963 and early 1964, informal discussions and an exchange of correspondence took place between the parties concerning additional space requirements of Penn State in said building or in an addition to be erected thereto. The lease agreement between the parties contained a number of provisions on this subject. They need not be considered, however, as they are not directly involved in this dispute.

On or about March 28, 1964, Penn State inquired of Hutchinson as to the possibilities of negotiating a cancellation of the lease for the balance of its term. Three days later, William Brody, a stranger to Hutchinson,2 approached Hutchinson and, as a result of a discussion between them, made a written offer to Hutchinson which he accepted. The offer stated:

“I would be willing to pay you the sum of thirty-four hundred eighty dollars ($3,480.00), as a consideration for the release of the Penn State Investors from their lease on the offices they occupy in the Park Plaza Building.
“This offer is contingent on the successful negotiations between me and the Penn State Investors for new offices”.

On April 2, 1964, Hutchinson made a written offer to Penn State to release it from its lease with him as follows:

[304]*304“I would be willing to release you from your lease under the following conditions;
“1 Vacate premises by May 15,1964
“2 That you will lease space from William Brody at 1005 Market Street, Lemoyne, Pa.
“3 That you will pay me one years rent in advance $3,480.00
“4 That this agreement has no bearing on any side agreement I have with Mr. William Brody”.

While there is conflicting testimony concerning Penn State’s acceptance of this offer, the jury verdict resolved this conflict in favor of plaintiff. Thereafter, Penn State leased office space from defendant Brody under the terms of which Penn State was given a reduction of rent for the first year of the term in the amount of $3,480, and Penn State vacated the premises leased to it by Hutchinson prior to May 15, 1964. After these events, neither Penn State nor Brody paid Hutchinson any sum of money. Hutchinson then brought this action claiming damages of $3,480 from each of defendants, Penn State and Brody, by separate counts in his complaint.3

It is Penn State’s contention that its agreement with Hutchinson is unenforceable for want of consideration inasmuch as he was already under legal obligation to Brody to release Penn State from its lease agreement with Hutchinson. This contention is found in a precept of contract law that a promise to do an act one is already bound to perform is not valid consideration.

Consideration has been defined as a benefit to the party promising or a loss or detriment to the party to whom the promise is made, and the consideration nec[305]*305essary to establish a valid contract must be an act, a forbearance or a return promise bargained for and given in exchange for the promise: Thomas v. R. J. Reynolds Tobacco Company, 350 Pa. 262 (1944).

As otherwise stated in Mikos v. Kida, 314 Pa. 561 (1934), at page 563:

“One of the tests of consideration is whether the promisee, at the instance of the promisor, has suffered any detriment, or whether in return for the promise he has done something that he was not bound to do or has promised to do some act or has abstained from doing something: Presbyterian Board of Foreign Missions v. Smith, 209 Pa. 361. There may even be a consideration without the accrual of any benefit at all to the promisor. If the promisee has suffered any detriment, however slight, or, though he has suffered no real detriment, if he has done what he was not otherwise bound to do, in return for the promise, he has given a consideration and the court will not ask whether the promisor was benefited”.

Applying these tests of legal consideration which are sufficient to support a contract, an analysis of the sundry promises made by and between Hutchinson and Penn State, and Hutchinson and Brody, discloses Valid consideration to support Penn State’s promise to pay Hutchinson the stated sum of money.

Hutchinson first contracted with Brody by promising to release Penn State from its lease with him in return for Brody’s promise to pay him $3,480. When entered into, this contract was both executory and conditional with both promises subject to Brody’s successfully negotiating a lease agreement with Penn State. At this juncture, therefore, the possibility existed that neither party would be required to perform their respective promises as they were wholly conditioned upon the action of a third party, Penn State, [306]*306on entering into a lease agreement with Brody. It must also be noted that no time limitation is contained in this Brody-Hutchinson contract and, therefore, it would be subject only to a test of reasonableness of time. However, at the moment Penn State entered into a lease agrément with Brody, the condition of the Brody-Hutchinson contract was met, Brody became obligated to pay Hutchinson $3,480 and Hutchinson was obligated to release Penn State from its lease agreement with him.

It is at this moment, Penn State contends, that its promise to pay Hutchinson $3,480 is not supported by valid consideration, as Hutchinson’s only promise to it under its ostensible agreement with Hutchinson is to release it from its lease, an obligation already required to be performed by Hutchinson under his contract with Brody. In support of its position, Penn State relies on the principle restated in Commonwealth Trust Company General Mortgage Investment Fund Case, 357 Pa. 349 (1947), at page 354:

“ ‘Where a legal obligation exists, a cumulative promise to perform it, unless upon a new consideration, is a nullity. Such promise adds nothing to and takes nothing from the original obligation. ... A promise cannot be conditioned on a promise to do a thing to which a party is already legally bound. . . .’: Wimer v. Overseers of the Poor of Worth Township, 104 Pa. 317, 320. Erny v. Sauer, 234 Pa. 330, 334, 83 A. 205. ‘A promise to do what the promisor is already bound to do cannot be a consideration, for if a person gets nothing in return for his promise but that to which he is already legally entitled, the consideration is unreal’: Quarture v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Schreckengost v. Kraft
204 A.2d 646 (Supreme Court of Pennsylvania, 1964)
Mikos v. Kida
172 A. 101 (Supreme Court of Pennsylvania, 1934)
Tradesmen's National Bank, Etc. v. Cummings Bros. Co.
159 A. 452 (Supreme Court of Pennsylvania, 1932)
Commonwealth Trust Co. General Mortgage Investment Fund Case
54 A.2d 649 (Supreme Court of Pennsylvania, 1947)
Thomas v. R. J. Reynolds Tobacco Co.
38 A.2d 61 (Supreme Court of Pennsylvania, 1944)
Murray v. Prudential Insurance Co. of America
18 A.2d 820 (Superior Court of Pennsylvania, 1940)
Quarture Et Ux. v. Allegheny Co.
14 A.2d 575 (Superior Court of Pennsylvania, 1940)
Wimer v. Overseers of the Poor
104 Pa. 317 (Supreme Court of Pennsylvania, 1883)
Presbyterian Board of Foreign Missions v. Smith
58 A. 689 (Supreme Court of Pennsylvania, 1904)
Erny v. Sauer
83 A. 205 (Supreme Court of Pennsylvania, 1912)

Cite This Page — Counsel Stack

Bluebook (online)
43 Pa. D. & C.2d 301, 1967 Pa. Dist. & Cnty. Dec. LEXIS 216, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hutchinson-v-penn-state-investors-life-insurance-pactcompldauphi-1967.