A past consideration will not generally be sufficient to support a contract. It is something done before the obligor makes his promise, and, therefore, cannot be a foundation for that promise, unless it lies been executed at the request (express or im plied) of the promisor. Such a request plainly implies a promise of fair and rea sonable compensation ; L. R. 8 Ch. 888; Car son v. Clark, 1 Scam. (Ill.) 113, 25 Am. Dec. 79 ; Doty v. Wilson, 14 Johns. (N. Y.) 378; Gleason v. Dyke, 22 Pick. (Mass.) 393: Hay den v. Inhabitants of Madison, 7 Greenl. (Me.) 76; Abbot v. Third School Dist, 7 Greenl. (Me.) 118; Comstock v. Smith, 7 Johns. (N. Y.) 87; Bulkley v. Landon, 2 Conn. 404; 1 Sm. Lead. Cas. 144, note to Lamp leigh v. Brathwait. But a pre-existing ob ligation will support a promise to perform that obligation which the law, in the case of a debt, will imply; Harriman, Contr. 83; 5 M. & W. 541; but a past consideration which did not raise an obligation at the time it, was furnished, will support no prom ise whatever ; 3 Q. B. 234; Harriman, Contr. 83; where there has been a request for serv ices, a subsequent promise to pay a definite sum for them is evidence of the actual value of the services; id. Where a creditor gives an extension of time for payment of a pre existing debt and takes a mortgage as se curity he is a purchaser for value; O'Brien v. Fleckenstein, 180 N. Y. 350, 73 N. E. 30, 105 Am. St. Rep. 768; the promise to pay for another's past services to and support of defendant's mother during an illness is val id; Montgomery v. Downey, 116 Ia. 632, 88 N. W. 810; but an agreement to take up al past due note without additional considera tion or a request or promise of forbear ance against the maker is without consid eration; J. H. Queal & Co. v. Peterson, 138 Ia. 514, 116 N. W. 593, 19 L. R. A. (N. S.) 842.
As to time, considerations may be of the past, present, or future. - Those which are present or future will support a contract not void for other reasons; Story, Contr. 71. When the consideration is to do a thing hereafter, and the promise has been accept ed, and a promise in return founded upon it, the latter promise rests upon sufficient foundation, and is obligatory ; Stewart v.
Redditt, 3 Md. 67; Hilton v. Southwick, 17 Me. 303, 35 Am. Dec. 253; Andrews v. Pon tue, 24 Wend. (N. Y.) 285; Gardner v. Web ber, 17 Pick. (Mass.) 407.
The adequacy of the consideration is gen erally immaterial; L. R. 5 Q. B. 87; 8 A. & E. 745; L. R. 7 Ex. 235; 5 C. B. N. S. 265; 24 L. J. C. P. 271; 16 East 372; Hesser v. Steiner, 5 W. & S. (Pa.) 476; Downing v. Funk, 5 Rawle (Pa.) 69; excepting formerly in England before 31 & 32 Vict. c. 4, in the case of the sale of a reversionary interest or where the inadequacy of the consideration is so gross as of itself to prove fraud or im position; Judy v. Louderman, 48 Ohio St. 562, 29 N. E. 181. There is no case where mere inadequacy of price, independent of other circumstances has been held sufficient to set aside a contract between parties stand ing on equal ground and dealing with each other without imposition or oppression ; Hind v. Holdship, 2 Watts (Pa.) 104, 26 Am. Dec. 107; Williams v. Jensen, 75 Mo. 681; Smock v. Pierson, 68 Ind. _405, 34 Am. Rep. 269; Wolford v. Powers, 85 Ind. 294, 44 Am. Rep. 16; Wells v. Tucker, 57 Vt. 227; Worth v. Case, 42 N. Y. 369. The adequacy of the consideration does not affect the con tract; Lawrence v. McCalmont, 2 How. (U. S.) 426, 11 L. Ed. 326; but the consideration must be real and not merely colorable; one cent has been held not to be a sufficient con sideration for a promise to pay $700; Schnell v. Nell, 17 Ind. 29, 79 Am. Dec. 453; and $1 has been held insufficient to support a prom ise to pay $1000; Shepard v. Rhodes, 7 R. I. 470, 84 Am. Dec. 573 ; a dollar would be a sufficient consideration for any promise ex cept one to pay a larger sum of money ab solutely; Lawrence v. McCalmont, 2 How. (U. S.) 426, 11 L. Ed. 326. A fully executed contract will not be disturbed for want of consideration; Lamb's Estate v. Morrow, 140 Ia. 89, 117 N. W. 1118, 18 L. R. A. (N. S.) 226.
See note to Chesterfield v. Jannsen in 1 W. & T. Lead. Cas.; CONTRACT.