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Angel v. Murray
Supreme Court of Rhode Island (1974) | 322 A.2d 630; 113 R.I. 482; 85 A.L.R. 3d 248; 1974 R.I. LEXIS 1202
TL;DR: A city's garbage collector encountered an unexpected, substantial increase in new homes. The city agreed to pay him more. The court upheld this contract modification, finding it enforceable even without new consideration because it was fair and based on unanticipated circumstances.
Legal Significance: This case is significant for adopting the modern exception to the pre-existing duty rule, as articulated in the Restatement (Second) of Contracts § 89. It allows for the enforcement of contract modifications that are fair and equitable in light of unanticipated circumstances.