Strong v. Sheffield
Court of Appeals of New York
39 N.E. 330 (1895)
Benjamin Strong (plaintiff) sold a business on credit to Gerardus Sheffield, memorialized in a demand promissory note; Louisa Sheffield (defendant), Gerardus's wife, later endorsed the note at Strong's request after Strong promised he would hold it and not collect until he decided he wanted the money. Strong actually held the note for two years before demanding payment, then sued Louisa for payment when Gerardus didn't pay; the trial court ruled for Strong, an intermediate appellate court reversed, and Strong appealed that reversal.
Whether a creditor's promise to forbear from collecting a debt can constitute valuable consideration for a third party's promise to answer for the debt, when the terms of the promise do not obligate the creditor to forbear for any length of time.