Seiberling,  122  Iowa,  522,  that  when  the  debtor  is  insolvent  the  agree-
ment of  the  creditor  to  accept  a  small  sum  in  satisfaction  is  valid.
No  reason  is  given  for  this  except  that  the  rule  in  question  is  "purely
technical".
*  It  appears  that  statutes  have  changed  the  rule  in  Alabama,  Cali-
fornia, Georgia,  North  Carolina  and  Virginia.  See  Herman  v.  Schles-
inger,  114  Wis.  382.  It  was  not  followed  in  Ford  r.  Hubinger,  64
Conn.  129 ;  Clayton  v.  Clark,  74  Miss.  499 ;  37  L.  R.  A.  771.
s  Very  v.  Levy.  13  Howard,  345 ;  Maddox  v.  Bevan,  39  Md.  499.
6  Chicora  Fer.  Co.  v.  Dunan.,  91  Md.  144 ;  Singer  v.  Lee,  105  Md.
663;  Savage  r.  Everman,  70  Pa.  319.
