POWERS COUPLED WITH AN INTEREST:' 26/ object? The object was to enable Mr. Phillips, the Vendor, to obtain his purchase money, and in the language of Williams, J., it therefore conferred a benefit on the donee of the authority.' " While in the cases just cited a common law power over property given for the benefit of the donee of the power is said to be " a power coupled with an interest," this view in many of the cases is not necessary to the decisions, and they could have been decided as they were in accordance with the principle in Hunt v. Rous- manier, without holding that the powers under consideration were coupled with interests. The issue in many of the cases (as, for instance, in the one last cited) was as to the revocability of the powers inter vivos ; they were powers given on valuable con- sideration as security to the donees, and such powers, though held in Hunt v. Rousmanier not to be coupled with an interest, were there declared to be irrevocable inter vivos. In the case of Jefifries, Administrator, v. The Mutual Life Insur- ance Company,^ recently decided by the Supreme Court of the United States, a meaning was attributed to the words " a power coupled with an interest " different from both of the two meanings above discussed. In this case the facts were that Charles W. Jeffries, administra- tor, employed Laurie and Crews, attorneys at law, to prosecute a claim against The Mutual Life Insurance Company of New York on a policy of life insurance given to his testator. Jeffries gave the attorneys full power to compromise the suit as they should please, and agreed that they should have a portion of the proceeds of the suit as compensation. The attorneys agreed with him to prosecute the claim. Charles W. Jeffries died during the pendency of the suit, and Cuthbert S. Jeffries, who had been made adminis- trator of the testator,* was substituted as plaintiff in the suit in 1873. In 1879 Laurie made a compromise with the Insurance Company and entered satisfaction in the suit, which the plaintiff sought to set aside. The issue in the case was whether the power to compromise given by the first administrator continued in force after his death. The Court on this subject said : — "The contract made by the first administrator having given to the attorneys a power coupled with an interest, the authority to compromise was not impaired by the death of the first administrator, and his successor was bound by the contract." 1 no U. S. 305. 35
