New York Court of Appeals

The Grocers’ Bank of the City of New York, Respondent v. Thomas D. Penfield, Impleaded

May 22, 187769 N.Y. 502

Summary

The Court of Appeals affirmed the lower court's order, holding that a holder who receives an accommodation promissory note as collateral for an antecedent debt, without any new consideration, is a holder for value and may enforce the note. The maker's lack of consideration is not a defence. The decision rests on established authority that the antecedent debt itself suffices as consideration.