After a lease has been executed,1 or a debt has been created,2 a promise by a third person to guarantee such lease or debt is not supported by the original consideration; nor is a promise to assume such debt supported by such debt as a consideration.3 Even if it is provided by statute that a pre-existing debt is a valuable consideration, a bank can not recover upon a note which was given as collateral security for a note held by such bank and signed by a corporation in which the bank's cashier was interested.4 A promise to indemnify a surety made after he became bound is void.5 If it is provided by statute that money which is deposited with an application for a liquor license shall be returned to the applicant if the license is refused, a promise by the treasurer to return such money to the party who advanced it to the applicant is without consideration.6 Examples of past acts which are not considerations for a subsequent express promise are: a written contract for the shipment of property, which has been already forwarded under a different oral contract;7 a promise to pay into a bank a commission which has

2 See Sec. 629.

3 See Sec. 629.

4 England. Hopkins v. Logan, 5 M. & W. 241.

Georgia. Monroe v. Martin, 137 Ga. 262, 73 S. E. 341.

Iowa. Meginnes v. McChesney, 179 la, 563, 160 N. W. 50 [sub nomine, Me-ginnes v. Copeland, L. R. A. 1917E, 1060].

Kentucky. Daviess County Bank & T. Co. v. Wright, 129 Ky. 21, 17 L. R. A. (N.S.) 1122, 110 S. W. 361, 33 Ky. L. Rep. 457; Foxworthy v. Adams, 136 Ky. 403, 27 L. R. A. (N.S.) 308, Ann. Cas. 1912A, 327, 124 S. W. 381; Young v. Exchange Bank, 152 Ky. 293, 153 S. W. 444.

Massachusetts. Widger v. Baxter, 190 Mass. 130, 3 L. R. A. (N.S.) 436, 76 N. E. 509.

Nebraska. Hauber v. Leibold, 76 Neb. 706, 107 N. W. 1042.

Tennessee. Citizens' Trust Co. v.

McDougald, 132 Tenn. 323, L. R. A. 1917C, 840, 178 S. W. 432.

Washington. Hemrich Bros. Brewing Co. v. Kitsap County, 45 Wash. 454, 9 L. R. A. (N.S.) 910, 88 Pac. 838.

5Lantz v. Ins. Co., 139 Pa. St. 546, 23 Am. St. Rep. 202, 10 L. R. A. 577, 21 Atl. 80.

6 Rudolph v. Hewitt, 11 S. D. 646, 80 N. W. 133.

7Schuler'v. Myton, 48 Kan. 282, 29 Pac. 163.

1 Griffin v. -Hoag, 105 la. 499, 75 N. W. 372; Macfarland v. Heim, 127 Mo. 327, 48 Am. St. Rep. 629, 29 S. W. 1030.

2 Alabama. Richardson v. Fields, 124 Ala. 535, 26 So. 981.

Arkansas. Summers v. Heard, 66 Ark. 550, 50 S. W. 78, 51 S. W. 1057.

California. Comstock v. Breed, 12 Cal. 286; Leverone v. Hildreth, 80 Cal. 139, 22 Pac. 72.

Illinois. Martin v. Stubbings, 20 111. App. 381.

Indiana. Sehnell v. Nell, 17 Ind. 29, 79 Am. Dec. 453; Davidson v. King, 51 Ind. 224; Wipperman v. Hardy, 17 Ind. App. 142, 46 N. E. 537.

Maine. Stevens v. Mayberry, 82 Me. 65, 19 Atl. 92.

Massachusetts. Tenney v. Prince, 21 Mass. (4 Pick.) 385, 16 Am. Dec. 347; Ellis v. Clark, 110 Mass. 389, 14 Am. Rep. 609; Pratt v. Hedden, 121 Mass. 116; Rogers v. Stone Co., 130 Mass. 581, 39 Am. Rep. 478.

Michigan. Kulenkamp v. Groff, 71 Mich. 675, 15 Am. St. Rep. 283, 1 L. R. A. 594, 40 N. W. 57; Fellows v. Thrall, S5 Mich. 161, 48 N. W. 506; Harrah v. Doherty, 111 Mich. 175, 69 N. W. 242.

Minnesota. Turle v. Sargent, 63 Minn. 211, 56 Am. St. Rep. 475, 65 N. W. 349.

Missouri. Moore v. Ry., 31 Mo. App. 145; Adams v. Huggins, 78 Mo. App. 219.

New Jersey. Pike v. Van Riper, 57 N. J. L. 290, 30 Atl. 529; Schaus v. Henry (N. J.), 99 Atl. 188.

Oklahoma. Clements v. Jackson County Oil & Gas Co. (Okla.), L. R. A. 1917C, 437, 161 Pac. 216.

Pennsylvania. Martin's Estate, 131 Pa. St. 638, 18 Atl. 987; Hess's Estate, 150 Pa. St. 346, 24 Atl. 676.

South Carolina. Gourdin v. Tren-holm, 25 S. Car. 362.

Texas. Baker v. Wahrmund, 5 Tex. Civ. App. 268, 23 S. W. 1023.

Vermont. Goddard's Estate, 66 Vt. 415, 29 Atl. 634.

Wisconsin. Bank v. Ross, 91 Wis. 320, 64 N. W. 993.

3 Richardson v. Fields, 124 Ala. 535, 26 So. 981; Barstow v. Ry. Co., 57 Ark. 334, 21 S. W. 652; Summers v. Heard, 66 Ark, 550, 50 S. W. 78, 51 S. W. 1057. (See especially report of this case in 21 S. W. 632.) Goddard's Estate, 66 Vt. 415, 29 Atl. 634.

4 Citizens' Trust Co. v. McDougald, 132 Tenn. 323, L. R. A. 1917C, 840, 178 S. W. 432.

5 Holloway's Assignee v. Rudy (Ky.), 60 S. W. 650 [sub nomine, Trimble v. Rudy (Ky.), 53 L. R. A. 353]; Daviess County Bank & T. Co. v. Wright (Ky.), 17 L. R. A. (N.S.) 1122, 110 S. W. 361, 33 Ky. L. Rep. 457.

6 Hemrich Bros. Brewing Co. v. Kitsap County, 45 Wash. 454, 9 L. R. A. (N.S.) 910, 88 Pac. 838.

7 Kentucky. Caldwell v. Felton (Ky.), 51 S. W. 575; Louisville, etc, Ry. v. Cooper (Ky.), 56 S. W. 144.

Massachusetts. Gott v. Dinsmore, 111 Mass. 45; Hendrick v. Ry., 170 Mass. 44, 48 N. E. 835.

been earned by one broker, so that a rival claimant of such commission could bring an action therefor; 8 a promise by an agent to pay accounts already made by him for his principal under his contract,9 or to become liable personally on his principal's pre-existing contract, made by him as agent,10 or to pay a part of the costs of an action which the agent's principal has brought to enforce a contract made through such agent with a third person,11 or to return money rightfully expended by him on behalf of his principal,12 or to pay to the principal the amount of money embezzled by a sub-agent, for which the agent was not liable;13 a promise by the pledgee for value of a note to deliver it to the assignee;14 a promise by one to whom money raised by mortgage is paid on a debt to "take care of" a prior encumbrance;15 a promise after mortgages were given that the first mortgagees would give the second mortgagees a share in the property mortgaged after sale and reorganization;16 a promise by a mortgagee to allow a subsequent creditor of the mortgagor to share in the security of the mortgage, which promise was made after such creditor had made the loan;17 a promise by a mortgagee that one who had advanced money to the mortgagor for the improvement of the mortgaged property should be repaid;18 a promise after a bond payable to A on order was given not to transfer it unless to B;19 a promise by a cashier of a bank to hold a partnership fund until the rights of the promisee as a partner were determined;20 a promise by the owner of a building to a materialman who has furnished materials to the contractor, to notify the materialman before he pays the contractor;21 a promise by C, the assignee of A, made after the assignment to him, to pay B, a creditor of A's, out of the claim when collected;22 a promise by the owner of a building to pay for brick properly rejected by the architect under the building contract;23 a warranty made after the sale is completed,24 or a promise to indemnify against loss therefrom;25 a promise made after the sale was completed, whereby the vendee agrees to pay more than the contract price;26 a promise by cne party after a contract has been made to advance money to the adversary party;27 a promise made after the sale of business and good-will not to engage in the same business,28 even if such promise is in writing and is attached to the original contract;29 a promise after a sale has been effected and insurance has been transferred, to secure the consent of the insurer to the transfer of such insurance;30 a promise by A to pay to B a commission for effecting the sale of property belonging to C, against whom A held claims for collection which were paid in part out of the proceeds of such sale, which promise was made after such sale;31 a promise to A to cancel a note executed by A in consideration of B's paying certain bonds on which A and B were liable as sureties, where B had already paid such bonds as receiver of the corporation which was primarily liable thereon, out of the assets of such corporation and under order of court, even if B had originally contributed the funds with which the property of such corporation "was bought;32 a promise by the owner of a bicycle to pay a mortgage given without his authority by one having no interest therein;33 a promise after performance of a contract to do extra work without compensation;34 a promise to indemnify a party to pending litigation;35 a promise to allow back interest on accounts that did not bear interest before a promise to pay it;36 or a promise after a settlement of an estate made by residuary legatees to pay certain undisposed of insurance policies to the widow.37 A note given by a woman as security for an existing debt of her husband is not founded on a valuable consideration.38 If the principal has elected to ratify an unauthorized contract of his agent and has accepted the benefits thereof, the subsequent promise of the agent to reimburse the principal for his expenditure under such contract is without consideration.39 If A, who is B's mother, has paid B's expenses of college, and such payment was not made under any agreement that B should reimburse A, B's subsequent promise to repay such expenses to A is not supported by a consideration.40 An advancement by a parent to his child is no consideration for a subsequent note given by the child.41 If a note which is signed by A, is delivered to B in reliance upon B's covenant not to sue A upon such note, A's subsequent promise to pay such note is without consideration.42 Payment of an obligation is no consideration for a subsequent note given by the payee to the maker.43 So a promise by an owner of land to pay for buildings erected or other improvements made on such land under circumstances creating no legal liability is void,44 as where a mortgagee promised, after enter-