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Who really said it

A Verbal Contract Isn't Worth the Paper It's Written On

Not Samuel Goldwyn — credited to Sir Bryan O'Loghlen Sir Bryan O’Loghlen 1828–1905 · Irish-born barrister & 13th Premier of Victoria, Australia
Disputed Free to reuse

Quote Investigator ↗ traces the gag to The Irish Law Times and Solicitors’ Journal of 14 June 1890, which reported that Sir Bryan O’Loghlen, M.P. — in the colony of Victoria — “gravely told the Supreme Court that ‘a verbal agreement is not worth the paper it’s written on.’” QI credits O’Loghlen while noting the same joke was circulating anonymously at the time, and hypothesises that Goldwyn never used the line at all: it only became his when Alva Johnston’s The Great Goldwyn (1937) ↗ printed it as a genuine Goldwynism.

Last verified 7 Sep 2026 · how we verify · spot an error?

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Disputed credit — copy with the correction

“A Verbal Contract Isn't Worth the Paper It's Written On” not Samuel Goldwyn. The joke was in print by 14 June 1890, when The Irish Law Times and Solicitors' Journal credited Sir Bryan O'Loghlen, and in this exact wording in the Cleveland Leader of 25 April 1905. Alva Johnston's The Great Goldwyn (Random House, 1937), p. 16, was the first book to print it as Goldwyn's; a Dallas Morning News column of 12 February 1956 reported Goldwyn denying the Goldwynisms attributed to him. Source: Quote Investigator, quoteinvestigator.com/2014/01/06/verbal-contract/ · Verbatim: “A verbal agreement is not worth the paper it's written on.”

The slide-ready mistake: crediting this to Samuel Goldwyn. Use the credit shown above instead.

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In context

Evoking the world of Sir Bryan O'Loghlen — Irish-born barrister & 13th Premier of Victoria. Theme: "A Verbal Contract Isn't Worth the Paper It's Written On". Atmospheric and restrained, cinematic directional light, a muted period-appropriate palette, fine grain and texture. Compose with generous empty space for the quote and a small credit line. No lettering in the image itself.

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Provenance

Where the line actually comes from

Earliest documented
The Irish Law Times and Solicitors’ Journal, 14 June 1890, p. 320
Exact modern wording
Cleveland Leader, 25 April 1905
First credited to Goldwyn
Alva Johnston, The Great Goldwyn (Random House, 1937), p. 16
Goldwyn’s response
Reported denying the Goldwynisms — Dallas Morning News, 12 February 1956

Sam said, “Gentlemen, include me out.” It would be impossible to make a more pointed remark than Goldwyn’s, “A verbal contract isn’t worth the paper it’s written on.” The Great Goldwyn, 1937, p. 16

In the paragraph immediately before this one, on the same page, Johnston concedes that “Goldwyn’s publicity department formerly collected and invented Goldwyn gags and circulated them,” and that “today it takes an expert to pick the genuine Goldwyn lines from the spurious.” He then files this line among the genuine ones — a line that had been in print since 1890.

Book scan
The Great Goldwyn (1937) on Internet Archive
Quote Investigator: the full 1890–1956 chronology

How we verified this

  • 14 June 1890 — The Irish Law Times and Solicitors’ Journal, p. 320, reports that “Sir Bryan O’Loghlen, M.P., who has a national right to indulge in this sort of thing, gravely told the Supreme Court that ‘a verbal agreement is not worth the paper it’s written on.’” This is the earliest instance Quote Investigator ↗ documents.
  • 1890–1905 — the joke spreads without an author. A September 1890 Rocky Mountain News item gives it to a stock Irish character; an 1894 collection credits “an Australian lawyer”; an 1897 review ties it to Sir Boyle Roche. The Cleveland Leader of 25 April 1905 prints the exact modern wording — “a verbal contract isn’t worth the paper it’s written on!” — in an anonymous dialogue, per QI ↗.
  • 12 December 1926 — comedian Ed Wynn runs it in his syndicated column in the Seattle Daily Times. QI ↗ notes he was using a jest already in circulation, not coining one.
  • 1937 — Alva Johnston’s The Great Goldwyn puts it in Goldwyn’s mouth on page 16 ↗ — the first attribution to him. By 12 February 1956 a Dallas Morning News column was reporting that Goldwyn “denies vehemently” the sayings pinned on him, listing a close variant of this one among them.
Public domain

The sentence itself is public domain in the United States: it is documented in print in The Irish Law Times and Solicitors’ Journal in June 1890 and in this exact wording in the Cleveland Leader of April 1905 — both decades before the 1931 US copyright threshold, and both by authors long dead. Note that the excerpt shown above is a short quotation from a separate and much later work, Alva Johnston’s The Great Goldwyn (Random House, 1937), reproduced here for commentary on how the misattribution began.

Rights status is our research, not legal advice — and copyright varies by country and edition. For commercial or published use, confirm with the rightsholder. See terms.

Fact-check

Who has been credited — and why it stuck to Goldwyn

Search the line today and almost every quotation site returns Samuel Goldwyn. The print record runs the other way: by the time Goldwyn was ever associated with it, the joke had been circulating for nearly five decades under several different names.

Samuel Goldwyn Misattributed

First printed as his in Alva Johnston’s The Great Goldwyn (1937), p. 16 — decades after the joke entered print. Quote Investigator ↗ states plainly that it “hypothesizes that Goldwyn never employed this phrase,” and Wikiquote ↗ lists it under Misattributed.

Ed Wynn Repeater, not originator

The comedian ran “A verbal contract, in my opinion, is not worth the paper it is written on” in his syndicated column in the Seattle Daily Times of 12 December 1926. QI ↗ notes he “used the jest when it was already in circulation.”

Sir Boyle Roche Folk origin

An 1897 item in The Contemporary Review connected the saying to Roche, per QI ↗. Roche is the figure most often called the “father” of the Irish bull ↗, which makes him a natural magnet for unattached examples of the form — the same role Goldwyn would later play.

Joseph M. Schenck, or Joseph L. Mankiewicz Rival theory

Wikiquote ↗ calls the famous line “a misreporting of an actual quote praising the trustworthiness of a colleague: ‘His verbal contract is worth more than the paper it’s written on’,” naming Schenck (Boller & George, They Never Said It, 1990, p. 42) or Mankiewicz (Easton, The Search for Sam Goldwyn, 1976). This could explain the transmission, but not the origin: the joke predates Goldwyn’s career.

The saying is documented in print from 14 June 1890 and in its exact modern wording by 25 April 1905, long before anyone attached it to Samuel Goldwyn — and in 1956 Goldwyn was reported denying the Goldwynisms hung on him. See the full chronology at Quote Investigator ↗.

Context

Why a nonsense sentence outlived the man it was pinned on

The line is a perfect Irish bull ↗ — a statement that collapses under its own logic while somehow still making its point. A verbal contract has no paper; that is the whole idea of it. The joke works because the speaker seems not to notice, and because the sentiment underneath (get it in writing) is sound legal advice. Nineteenth-century law reporters loved that combination, which is exactly why The Irish Law Times printed it in 1890 as a specimen of the form rather than as a piece of wisdom.

Samuel Goldwyn’s role came later, and it was structural rather than personal. By the 1930s he had become what Quote Investigator calls “a magnet for malapropisms” — an address that unattached jokes were simply delivered to. Alva Johnston, writing the first book-length portrait of him in 1937, described the mechanism on the very page where he then repeated this line as authentic: Goldwyn’s publicity department had collected and invented gags and put them into circulation, until “it takes an expert to pick the genuine Goldwyn lines from the spurious.” Johnston diagnosed the disease and caught it in the same breath.

A verbal contract has no paper. That is the joke — and it was being told in courtrooms decades before Hollywood existed.

The rival theory: an inverted compliment

Wikiquote’s Misattributed section ↗ offers a different explanation of how the sentence reached Goldwyn: that it is a garbling of a real compliment he paid a colleague — “His verbal contract is worth more than the paper it’s written on” — the colleague being identified as Joseph M. Schenck in Paul F. Boller and John George’s They Never Said It (1990), p. 42, or as Joseph L. Mankiewicz in Carol Easton’s The Search for Sam Goldwyn (1976).

That story may well explain why the line stuck to Goldwyn so firmly. It cannot explain where the line came from, because the joke was in print in 1890 and in its exact modern wording in 1905, well before Goldwyn was a producer. Treat it as a plausible account of the transmission, not of the origin.

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Dig deeper

Trusted places to keep pulling the thread — primary archives, fact-checks, and scholarship. We show how we used each one before you leave.

Quote Origin: A Verbal Contract Isn't Worth the Paper It's Written Onquoteinvestigator.com

The anchor investigation. Dated citations from 1890 to 1956 and QI's hypothesis that Goldwyn never used the phrase.
The Great Goldwyn (1937), p. 16archive.org

Alva Johnston's biography — the first book to print the line as Goldwyn's, on the same page where he admits publicists invented Goldwyn gags.
Samuel Goldwyn — Misattributeden.wikiquote.org

Files the line under Misattributed and sets out the rival 'misreported compliment' theory, citing Boller & George (1990) and Easton (1976).
Samuel Goldwynen.wikipedia.org

Biography, and the note that Goldwynisms 'were the inventions of humorists and newspaper editors' and many predate his career.
Bryan O'Loghlenen.wikipedia.org

Life dates and offices of the barrister and Premier of Victoria whom The Irish Law Times credited in 1890.
Irish bullen.wikipedia.org

Defines the joke form this sentence belongs to and names Sir Boyle Roche as its traditional 'father'.

The man Quote Investigator actually credits

The Irish barrister who out-Goldwyned Goldwyn

Sir Bryan O’Loghlen

1828–1905 · Irish-born barrister & 13th Premier of Victoria

Sir Bryan O’Loghlen, 3rd Baronet, was admitted to the Irish Bar in 1856, emigrated to Australia and served as a Crown Prosecutor in Victoria from 1863, then as the colony’s Attorney-General and, from 1881 to 1883, as its 13th Premier. He is the figure The Irish Law Times named in 1890 as the man who told the Supreme Court that a verbal agreement was not worth the paper it was written on — a remark the journal treated as a splendid specimen of the Irish bull. Quote Investigator calls it reasonable to credit him, while cautioning that the same joke was already being told by anonymous characters in newspaper gags, so the ascription may itself have been manufactured.

For writers & researchers

Cite this

Earliest documented instance

Earliest documented in The Irish Law Times and Solicitors’ Journal, 14 June 1890, 320, quoted in “Quote Origin: A Verbal Contract Isn’t Worth the Paper It’s Written On,” Quote Investigator, 6 January 2014. First attributed to Samuel Goldwyn in Alva Johnston, The Great Goldwyn (New York: Random House, 1937), 16.

This verification page

Quotle.info. “Who really said ‘A Verbal Contract Isn't Worth the Paper It's Written On’?” Last verified 7 Sep 2026. https://quotle.info/who-said/a-verbal-contract-isnt-worth-the-paper-its-written-on/

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