Whitten v. Greeley-Shaw

During an affair, Whitten (plaintiff) funded a house purchase for Greeley-Shaw (defendant), who signed a promissory note and mortgage in his favor. Greeley-Shaw later drafted and Whitten signed a one-page document promising her monthly payments, home repairs, medical costs, an annual trip and jewelry, and regular contact, in which she in turn promised not to call his home or office without permission -- a term she added because she felt he should get something in return. When Whitten later sought foreclosure for nonpayment on the note, Greeley-Shaw counterclaimed to enforce the document; the trial court found no enforceable contract and ruled against her, and she appealed.

Whether a party's promise that was not bargained for by the other party can serve as consideration to support the other party's promise.