Past services, when rendered under such circumstances as to create no legal liability, are not a consideration for a subsequent promise.1 Illustrations of such services are those rendered by father to son;2 past services rendered to a father by his daughters without any agreement for compensation,3 services rendered by a niece living in the family;4 services rendered by B while living in A's family as a daughter, although in fact no relation;5 support, furnished a minor daughter by her mother;6 or medical attendance rendered to an adult, for which his parent subsequently promises payment.7 The fact that services were rendered by B to A in A's lifetime is not a consideration for a promise by A's wife, which is made after A's death to compensate B therefor.8 A promise to pay an additional sum for services already performed and paid for under a contract has no consideration.9 A clairvoyant predicted A's death within twelve months. A contract to give to her a note and mortgage executed by her if her prediction came true, in consideration of "certain business and test sittings," was held to be without consideration, as it did not appear that any liability was created by the sittings themselves.10 A, who was indebted to B, accepted certain employment from X. Subsequently B promised to A an extension of time in consideration of A's accepting such employment. It was held that A's acceptance of such employment was not a consideration for B's promise to extend the time of such obligation.11

54 Western Paving Co. v. Ry., 128 Ind. 525, 25 Am. St. Rep. 462, 10 L. R. A 770, 26 N. E. 188, 28 N. E. 88.

1 Arizona. Wulff v. Lindsay, 8 Ariz. 168, 71 Pac. 963.

Illinois. People v. Porter (111.), 123 N. E. 59.

Iowa. Allen v. Bryson, 67 la. 591, 56 Am. Rep. 358, 25 N. W. 820; Walker v. Irwin, 94 la. 448, 62 N. W. 785; Gooch v. Gooch, 178 la. 902, L. R. A. 1917C, 582, 160 N. W. 333. Maryland. Harper v. Davis, 115 Md. 349, 35 L. R. A. (N.S.) 1026, 80 Atl. 1012.

Massachusetts. Chamberlin v. Whit-ford, 102 Mass. 448; Morse v. Mason, 103 Mass. 560; Conant v. Evans, 202 Mass. 34, 88 N. E. 438.

New York. Frear v. Hardenbergh, 5 Johns. (N. Y.) 272, 4 Am. Dec. 356.

Tennessee. Shugart v. Shugart, 111 Tenn. 179, 76 S. W. 821. So a note given by a candidate for past political services not rendered at his request is void. Dearborn v. Bowman, 44 Mass. (3 Met.) 155.

2Stoneburner v. Motley, 95 Va. 784, 30 S. E. 364 [citing, Wennall v. Ad-ney, 3 Bos. & Pul. 247; Cook v. Bradley, 7 Conn. 57, 18 Am. Dec. 79; Mills v. Wyman, 20 Mass. (3 Pick.) 207; Hack v. Stewart, 8 Pa. St. 213].

8 Fair Haven Marble, etc., Co. v. Owens, 69 Vt. 246, 37 Atl. 749.

4 Robinson v. McAfee, 59 Mich. 375, 26 N. W. 643.

5 Harper v. Davis, 115 Md. 349, 35 L. R. A. (N.S.) 1026, 80 Atl. 1012.

6 Perkins v. Westcoat, 3 Colo. App. 338, 33 Pac. 139.

7 Mills v. Wyman, 20 Mass. (3 Pick.) 207; Rankin v. Beale, 68 Ma App. 325.

8Royer v. Kelly, 174 Cal. 70, 161 Pac. 1148.

9 Parsons v. Teller, 188 N. Y. 318, 80 N. E. 930.