An important part of any contract is consideration, but courts have found a wide variety of things to count as consideration. For example, in Earle v. Angell (157 Mass. 294, 32 N.E. 164 (Mass. 1892)), an aunt told her nephew that if he attended her funeral, he would get $500. He did. When the estate wouldn’t pay, he sued for breach of contract. Although the estate argued that the aunt (being dead at the time) received nothing by her nephew’s attendance at her funeral, the Court found that there was consideration, even though the nephew’s performance occurred after the Aunt’s death. The Court found that what the aunt received for her $500 was ‘peace of mind’ while she was alive.