## Facts

- Sheldon Clark, an elderly and seriously ill man, frequently stayed in the home of Charles Clark and his wife.
- The Clarks provided lodging and personal services beyond ordinary hospitality, including household work and care during illness.
- During the period of care, Sheldon repeatedly stated that he intended to pay the Clarks for their services.
- Shortly before his death, Sheldon executed a $700 promissory note payable to the Clarks, reciting “for value received.”
- After Sheldon’s death, the estate refused payment, asserting the note was a gratuitous promise unsupported by consideration.
- A trial-level court agreed with the estate and treated the note as unenforceable for lack of consideration.

## Issues

1. Whether the Clarks’ lodging and caretaking services constituted legally sufficient consideration to support Sheldon’s $700 promissory note enforceable against his estate.
2. Whether the note could be invalidated on the ground that the amount promised exceeded the reasonable value of the services.

## Decision

- The Supreme Court of Errors of Connecticut held the note was supported by consideration and enforceable against the estate.
- The court rejected the view that the note failed for lack of consideration where the services were rendered under circumstances indicating an expectation of compensation.
- The court treated the alleged “overpayment” as an adequacy objection, not a failure of consideration, and declined to substitute its valuation for the promisor’s.
- The trial court’s contrary conclusion was error, and the claimants were entitled to recover on the note.

## Legal Principles

- Services rendered to a promisor may constitute sufficient consideration when the circumstances show they were not intended as a mere gratuity and were furnished with an expectation of payment.
- Courts distinguish between the existence of consideration (required) and the adequacy of consideration (generally not reviewed); a bargain does not fail merely because the promisor agreed to pay more than others might.
- A promissory note reciting “for value received,” combined with surrounding facts showing compensable services, supports treating the obligation as contractual rather than donative.

## Conclusion

A promissory note given in recognition of lodging and caretaking services was enforceable because the services supplied legally sufficient consideration, and the court would not invalidate the note merely because the amount appeared generous relative to the services provided.


Appeal of Clark, 19 A. 332 (Conn. 1889)