In Almeida v. Almeida, 4 Haw. App. 513, 669 P.2d 174 (Haw. Ct. App. 1983), plaintiff conveyed property to herself and defendant, her son, as joint tenants. The deed itself did not recite a covenant or condition that defendant care for plaintiff in her old age. Defendant argued the conveyance was therefore a gift with no such condition. The trial court found defendant's promise was consideration for the conveyance, and divested defendant of the property. 669 P.2d at 179. In affirming, the Hawaii Court of Appeal found clear and convincing evidence of defendant's promise in the testimony of plaintiff and one of her sons. Id. The court noted that where the consideration for a deed depends upon a promise of support, courts have shown more leniency toward the grantor, "particularly where the grantor is of advanced years." Id. at 181.