Quigley v. Wilson

474 N.W.2d 277 · Court of Appeals of Iowa · 1991

Facts

Lester Quigley, Sr. sold his farm to Donald and Janis Wilson on contract. After the Wilsons' assignee returned the farm and the Wilsons faced financial difficulties, Quigley, Sr. and the Wilsons renegotiated the contract, reducing the price and altering terms in a 1986 agreement. Quigley, Sr.'s conservators later sued, claiming the Wilsons defaulted on the original contract and the 1986 agreement lacked consideration, but the trial court found Quigley, Sr. competent and the 1986 agreement enforceable.

Issue

Did the trial court err by not allowing the issue of lack of consideration for the 1986 contract modification to be presented to the jury, and was the 1986 agreement enforceable despite the alleged lack of consideration?

Holding

The appellate court affirmed the trial court's decision, finding that while the trial court erred in its reasoning for not allowing the consideration issue to the jury, the 1986 agreement was enforceable as a valid modification under the Restatement (Second) of Contracts § 89D.

Rule

A promise modifying a duty under a contract not fully performed on either side is binding if the modification is fair and equitable in view of circumstances not anticipated by the parties when the contract was made, such as a drastic decrease in land value or buyer's financial hardship.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.