## Facts

- Charles Lehman, an elderly widower and longtime friend of Wolford, asked Wolford to name his newborn son after him and promised to provide generously for the child’s welfare and education.
- Wolford named the child Charles Lehman Wolford in reliance on Lehman’s request and promise.
- Afterward, Lehman frequently visited Wolford’s home and, at Lehman’s request, Wolford and his wife cared for him during periods of illness; Wolford also arranged carriage rides for Lehman.
- When the child was about five months old, Lehman executed a $10,000 promissory note payable to Wolford, stating this was his preferred method of carrying out the earlier promise rather than making a will provision or immediate conveyance.
- After Lehman died, Wolford sued Lehman’s estate (represented by Powers) to recover on the note.
- The trial court entered judgment for the estate, concluding the note lacked sufficient consideration, and Wolford appealed.

## Issues

1. Whether the $10,000 promissory note was supported by legally sufficient consideration, making it enforceable against the promisor’s estate.
2. Whether naming a child as requested by the promisor can constitute a legal detriment sufficient to supply consideration.
3. Whether requested personal care and related services provided to the promisor can constitute consideration, as opposed to the note being a mere gratuitous promise.

## Decision

- The Indiana Supreme Court reversed the judgment for the estate.
- The court held the promissory note was supported by sufficient consideration and was enforceable against Lehman’s estate.
- The court treated both the naming of the child at Lehman’s request and the requested services rendered to Lehman as supporting consideration.
- The court rejected the characterization of the note as a purely donative instrument.

## Legal Principles

- A promise is enforceable where the promisee undertakes a bargained-for legal detriment or confers a bargained-for benefit, even if the promisor’s motives include affection or sentiment.
- Surrendering freedom of choice in response to a request (such as agreeing to name a child in a particular manner) can constitute a legally sufficient detriment for consideration purposes.
- Services rendered at the promisor’s request may supply consideration supporting a later promissory note.
- Courts generally do not assess the adequacy or equivalence of consideration once a real bargained-for detriment/benefit is shown.

## Conclusion

The court enforced the $10,000 note against the estate because Wolford’s performance—naming his child as requested and providing requested care and assistance—constituted sufficient consideration, and the law does not require the exchange to be economically equivalent to be binding.


Wolford v. Powers, 85 Ind. 294 (Ind. 1882)