New York Court of Appeals
Augusta G. Genet, Appellant v. the President
January 17, 1893136 N.Y. 593
Summary
The Court held that the written memorandum was an executory lease of mineral product, not a deed conveying the coal veins in fee, and that an implied covenant of good faith and fair dealing prohibited the lessee from wilfully or negligently destroying the mine, giving the lessor a cause of action for breach.