In the law of contract, a good consideration, as distinguished from a valuable consideration, is inoperative, and is insufficient to support a promise.1

6 Berry v. Graddy, 58 Ky. (1 Met.) 553.

7 Arnold v. Park, 71 Ky. (8 Bush) 3.

8 Mark v. Clark, 50 Ky. (11 B. Mon.) 44.

9 Bufford v. McKee, 31 Ky. (1 Dana) 107.

10Candee v. Connecticut Savings Bank, 81 Conn. 372. 71 Atl. 551; Gooch v. Gooch, 178 la. 902, L. R. A. 1917C, 582, 160 N. W. 333; Doty v. Dickey (Ky.), 96 8. W. 544.

11 Gooch v. Gooch, 178 la. 902, L. It A. 1917C, 582, 160 N. W. 333.

12Doty v. Dickey (Ky.), 96 S. W. 544.

13Candee v. Connecticut Savings Bank, 81 Conn. 372, 71 Atl. 551.

14 Sullivan v. Sullivan, 122 Ky. 707,

7 L. R. A. (N.S.) 156, 92 S. W. 966.

15 See Sec. 519 et seq.

1 England. Holliday v. Atkinson, 5 Barn. & Cr. 501; Tweddle v. Atkinson, 1 B. & S. 393; Hill v. Wilson, L. R.

8 Ch. App. Cases, 888.

A promissory note, executed by a parent and delivered to his child upon consideration of love and affection, is unenforceable.2 A son, to whom his mother has given a written order upon trustees, without any consideration except love and affection, can not maintain an action against her, on the refusal of the trustees to pay such order.3 A promise by a devisee, made after testatrix's death, to divide his property with his brother, though both were sons of testatrix, is without consideration.4 A conveyed land to his daughter B, by a deed which was given for love and affection, and which contained a covenant by A to pay off certain mortgages on such land as they became due. Such covenant was held to be unenforceable for want of consideration.5

California. Peek v. Peek, 77 Gal. 106, 11 Am. St. Rep. 244, 1 L. R. A. 185, 19 Pac. 227; Tracy v. Alvord, 118 Cal. 654, 50 Pac. 757.

Georgia. Wright v. Threatt, 146 Ga. 778, 92 S. E. 640.

Illinois. Geer v. Goudy, 174 111. 514, 51 N. E. 623; Schwerdt v. Schwerdt, 235 111. 386, 85 N. E. 673.

Maine. Maynard v. Maynard, 105 Me. 567, 75 Atl. 299.

Massachusetts. Phillips v. Graham, 96 Mass. (14 All.) 36; Chase v. Chase, 191 Mass. 556, 78 N. E. 115.

Michigan. Conrad v. Manning, 125 Mich. 77, 83 N. W. 1038.

New York. White v. White, 52 N. Y. 368; Parsons v. Teller, 188 N. Y. 318, 80 N. E. 930.

Pennsylvania. Kennedy v. Ware, 1 Pa. St. 445, 44 Am. Dec. 145; In re Kern's Estate, 171 Pa. St. 55, 33 Atl. 129.

Rhode Island. Wilbur v. Wilbur, 17 R. I. 295, 21 Atl. 497.

South Carolina. Priester v. Priester, Rich. Eq. Cas. 26, 23 Am. Dec. 191.

Tennessee. Shugart v. Shugart, 111 Tenn. 179, 102 Am. St. Rep. 777, 76 S. W. 821.

Virginia. Keffer v. Grayson, 76 Va. 517, 44 Am. Rep. 171; PennyPac.ker v. Maupin, 96 Va. 461, 31 S. E. 607.

2 Illinois. Blanchard 7. Williamson, 70 111. 647.

Kentucky. Sullivan v. Sullivan, 122 Ky. 707, 7 L. R. A. (N.S.) 156 (note), 92 S. W. 966.

Massachusetts. Parish v. Stone, 31 Mass. (14 Pick.) 198, 25 Am. Dec. 378.

Michigan. Conrad v. Manning, 125 Mich'. 77, 83 N. W. 1038.

New Hampshire. Sanborn v. Sanborn, 65 N. H. 172, 18 Atl. 233.

New Jersey. Smith v. Smith, 30 N. J. Eq. 564.

New York. Fink v. Cox, 18 Johns. (N. Y.) 145, 9 Am. Dec. 191.

Ohio. Starr v. Starr, 9 O. S. 74.

South Carolina. Priester v. Priester, Rich. Eq. Cas. 26, 23 Am. Dec. 191.

Tennessee. Shugart v. Shugart; 111 Tenn. 179, 102 Am. St. Rep. 777, 76 S. W. 821.

Vermont. Holley v. Adams, 16 Vt. 206, 42 Am. Dec. 508; Smith v. Kitt-ridge, 21 Vt. 238.

3 Maynard v. Maynard, 105 Me. 567, 75 Atl. 299.

4 Chase v. Chase, 191 Mass. 556, 78 N. E. 115.

5 Fisher v. Union Trust Co., 138 Mich. 612, 110 Am. St. Rep. 329, 68 L. R. A. 987, 101 N. W. 852.

In other jurisdictions it has been held that love and affection are a sufficient consideration for an agreement between parent and child.6 A written promise by A to pay a certain sum of money to her adopted child B, is said not to need any further consideration than the natural love and affection existing between the parties.7 The courts are, however, still very zealous, as a rule, to find a valuable consideration to supplement a good consideration where the transaction is a fair one.8

If the contract is on a valuable consideration, however, the fact that affection is an additional consideration will not invalidate the contract.9

When the courts are not discussing good consideration in the technical sense of the term, but are really discussing valuable consideration, they frequently use the word "good" as equivalent to "sufficient"; that is, both valuable and adequate. The confusion is usually one of words only.

If love and affection between persons related by ties of blood or marriage are not a consideration at contract law, it is even clearer that actual affection is a motive for a promise, but it is not a consideration therefor.10 If B had taken care of A when A was a child and had been paid therefor in full, A's subsequent promise in consideration of such services to pay to B a certain sum annually for B's life, is not supported by any consideration.11