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P sued D for $200, the real estate commission due on the sale of D’s property. The law requires such broker contracts to be in writing, and P made the sale for D before the writing. The broker contract was put in writing after the sale had been made. Nonetheless, on or about the 21st day of November, 1906, D made, executed, and delivered to P their written agreement agreeing to pay P two hundred dollars ($ 200) for his services in selling for them a certain parcel of real estate. D refused to pay as there was no consideration for the after-the-fact commission agreement, as the consideration was past consideration. The trial court found for P, claiming that there was a moral obligation for D to pay P and that moral obligation was enough to validate past consideration and make the contract enforceable. D appealed.

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