New York Court of Appeals
Charles B. Benedict, Appellants v. Giles Cowden, Respondent
May 21, 187249 N.Y. 396
Summary
The New York Court of Appeals affirmed the lower court, holding that a memorandum attached to a promissory note at the time of its execution is a substantive part of the contract. Its removal without the maker's consent constitutes a material alteration that destroys the note even in the hands of an innocent indorsee.