 For example, in the 1904 case "Fischer v. Union Trust Co.", the Michigan Supreme Court held that the one dollar paid for the sale of real property did not constitute valuable consideration since the transaction had not been bargained for—a dollar was handed to a mentally incompetent "buyer" who then dutifully handed it to the "seller".The dollar was not considered real consideration, not because the dollar was too small an amount, but because it did not induce the seller to part with the property.Such promises that are motivated by love and affection are insufficient to constitute consideration.