Quigley v. Wilson
474 N.W.2d 277 · Court of Appeals of Iowa · 1991
Facts
Lester Quigley, Sr. sold a farm to the Wilsons, who later struggled to make payments. They renegotiated the contract in 1986, reducing the price and altering terms. Quigley's conservators later sued, seeking a declaratory judgment that the Wilsons were in default of the original 1980 contract, arguing the 1986 agreement lacked consideration.
Issue
Did the trial court err by preventing the conservators from arguing lack of consideration to the jury, and was the 1986 contract modification enforceable despite the alleged lack of consideration?
Holding
The appellate court affirmed the trial court's finding that the 1986 agreement was enforceable. While the trial court erred in its procedural reasoning regarding the lack of consideration defense, the modification was valid under the Restatement (Second) of Contracts § 89D due to unanticipated circumstances.
Rule
A promise modifying a duty under a contract not fully performed on either side is binding if the modification is fair and equitable in view of circumstances not anticipated by the parties when the contract was made.
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