Whether the plaintiff's voluntary rescue of the defendant supplied consideration sufficient to make the defendant's later promise to pay her damages enforceable.
Holding
No. The plaintiff's humanitarian rescue, though it saved the defendant's life and caused her serious injury, was not legal consideration for his later promise.
Reasoning
The Court treated the defendant's promise as one made after the plaintiff had already acted. The complaint alleged that the plaintiff intervened voluntarily to prevent the defendant's wife from killing him, was injured in doing so, and only afterward received his promise of payment.
A moral obligation or a sense of gratitude is not enough to create an enforceable contract. The Court acknowledged that the defendant ought, as a matter of common gratitude, to compensate the plaintiff for the injury she suffered while saving him.
But the law requires consideration recognized by contract law, not merely a prior humanitarian act. Because the plaintiff's voluntary rescue did not constitute such consideration for the defendant's subsequent promise, the promise was unenforceable.