This section contains the nature of the case and procedural background.

Rye (P) sued upon a promissory note and Phillips (D) plead an accord and satisfaction. P objected to the introduction of the accord and satisfaction evidence at trial, and that was sustained. P then motioned for a directed verdict which was granted; a mere promise of a creditor to receive, and of the debtor to pay, a sum less than the debt in full satisfaction of it is without consideration and binds neither party. D motioned for a new trial, that was denied, and D appealed.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.