In a recent Washington case, Paulsen Estate, Inc. v. Naches-Selah Irrigation District, the Supreme Court was called upon to decide whether the payment of the liquidated portion of a debt was a sufficient consideration for the discharge of the remaining part which was disputed by the parties. The court's decision that the debtor was thereby discharged presents a phase of accord and satisfaction which has had a peculiar history in this state.
Payment of the Liquidated Portion of a Debt as Consideration for the Discharge of the Entire Claim,
13 Wash. L. Rev. & St. B.J.
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