Written document failed to include any conditions on effectiveness of gift
An appellate court in New York has affirmed an order enforcing $900,000 in pledges from a foundation to St. Bonaventure University and dismissing a declaratory judgment action seeking to invalidate them. The University had obtained the pledges as part of a capital campaign to expand its library. The foundation argued that the pledges should not be enforced because they were subject to certain conditions and restrictions that were not stated in the pledge agreements. The Court said that when a pledge is made in writing, unless conditions are expressed or at least implied in the document, state law prevents evidence beyond the written document from being used to prove such conditions, except to show a condition precedent that would cause the agreement to be ineffective.