A transaction between a religious adviser and a member of his parish or congregation advantageous to such adviser is generally held to be presumptively due to undue influence.1 A transaction between a spiritualistic medium and a believer in his powers resulting in benefit to the medium creates a presumption of undue influence.2 Notes which are given by one who is apparently incompetent, and who gives such notes, by reason of his belief in faith cure, to a representative of such organization, will be held to be invalid.3