New York Court of Appeals

Jane McKenzie, Respondents v. Charles Harrison, Appellants

April 22, 1890120 N.Y. 260

Summary

The Court reversed the judgment, holding that an oral agreement to reduce rent that had been fully executed—payments made and receipts given—cannot be revoked, that the evidence of that agreement should have been admitted, and that the rule that a lesser payment cannot constitute accord and satisfaction does not apply when the agreement is executed.