When the power of an agent is coupled with an interest it is irrevocable. The meaning of the words "coupled with an interest" has not been very accurately defined. They certainly mean something more than a contract on the part of the principal that the agency shall not be revoked. In spite of such a contract, an agency may be revoked though a principal will thereupon become liable for damages.61 There must be an
Fuller v. Emerson, 7 Cush. 203; Wilson v. Harris, 21 Mont. 374, 54 Pac. 46; Elwell v. Coon (N. J. L.), 46 Atl. 580.
52 Bx parte Snowball, L. R. 7 Ch. 634, 548; In re Oriental Bank Corp., 28 Ch. D. 634, 640.
53 Hudson v. Granger, 5 B. & Ald. 27; Audenried v. Betteley, 8 Allen, 302; Cushman v. Snow, 186 Mas. 169, 71 N. E. 529.
54 Hudson p. Granger, 5 B. & Ald. 27.
55 In re Oriental Bank Corp., 28 Ch. D. 634,640.
56 See supra, Sec. 265.
57 See Chamley v. Winstanley, 5 East, 266.
58See supra, Sec.269; also Wambole v. Foote, 2 Dak. 1, 2 N. W. 239.
59Brown v. Miller, 46 Mo. App. 1; Henderson v. Ford, 46 Tex. 627; compare Joseph v. Fisher, 122 2nd. 399, 23 N. E. 856.
60See Insurance Co. v. Davis, 95 U. S. 425, 24 L. Ed. 463; Williams v. Paine, 169 U. S. 55, 74, 42 L. Ed. 658, 18 S. Ct. 279.
61 Duvia v. Cotton States L. Ins. Co., 232 Fed. 343, 146 C. C. A. 391; Coney v. Sanders, 28 Ga. 511; Feldman interest in properly to which the agency is subservient, as when the agency is intended to enable the person to whom it is given to collect property or realize its value.62 The interest which the agent would derive from compensation for his services as agent, even though this compensation is to be paid out of property to which the agency relates, is not a sufficient interest within the meaning of the rule.63