Angel v. Murray, 113 R.I. 482, 322 A.2d 630 (1974), was a case decided by the Rhode Island Supreme Court that first accepted the rule articulated in the Uniform Commercial Code §2-209(1) and the Restatement Second of Contracts §89(a) that the modification of a contract does not require its own consideration if the modification was made in good faith and was voluntarily accepted by both parties.

In 1967 Maher requested an additional $10,000 per year for refuse collection because of an unexpected increase in the number of dwellings in the city.

To determine if the modification met the standard of good faith, the Court looked to §89(a) of the Restatement Second of Contracts.

[3] Angel v. Murray presents an exception to the pre-existing duty rule that would have normally required Maher to collect all of the refuse for the same pay.

The case is an example of the somewhat amorphous "unanticipated circumstances" exception to the pre-existing duty rule when courts will often invalidate contract modifications based on economic duress.