Consolidated Freightways Corp. of Delaware v. Williams

Court of Appeals of Georgia · 1976 · Contracts

ContractsRewardsUnilateral contractsContract interpretationreward offerunilateral contractacceptance by performanceemployee eligibility

Facts

The employer posted a sign at its terminal offering "Up to $5,000 reward" for information leading to the arrest and conviction of any individual found stealing or concealing the employer's property. The plaintiff, a dock foreman, knew of the posted reward and took steps to observe an employee stealing, including having someone temporarily assume his duties while he hid in a trailer to watch unseen. The information he furnished led to the arrest and conviction of the thief, but the employer refused to pay the reward. The employer contended that supervisors were not included in the offer, that the plaintiff had not acted in reliance on the reward, that the offer was too indefinite, and that reporting theft was already within the plaintiff's job duties.

Issue

Whether the employee could recover under the employer's posted reward offer where he was a supervisor, was aware of the offer but did not testify that reward was his exclusive motive, the offer promised "up to $5,000," and the employer argued that detecting and reporting theft was already part of his employment duties. Also at issue was whether the trial court erred in denying the employer's directed-verdict motions and in its jury instructions.

Rule

A general published reward offer is a unilateral contract offer that is accepted by the requested performance unless the offer specifies otherwise. In construing such an offer, the court looks to the contract as a whole, favors a construction that upholds the contract and advances its beneficial purpose, and construes doubtful language most strongly against the offeror. The offeree need not act with absolute or exclusive reliance on the reward so long as he knew of the offer and performed the requested act. A reward claim is not defeated as a matter of law by an employer's assertion that the employee acted within the scope of employment where the evidence authorizes a finding that the employee rendered services beyond routine duties.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Pine Harbor Logistics posted notices at its Columbus, Georgia warehouse stating: "Reward up to $4,000 for information leading to the arrest and conviction of anyone stealing company property. Report in confidence to your manager or regional office." Dana Mercer, an evening shift lead who reported to an operations manager, knew of the notice, conducted extra after-hours observation, and supplied information that led to arrest and conviction.

If Pine Harbor refuses to pay on the ground that shift leads were never meant to qualify because the notice says to report to "your manager," which is the best answer?

Explanation. A published reward offer is construed as a unilateral contract offer. When the wording is general and does not explicitly limit the class of offerees, the court reads the offer as a whole, favors a construction that upholds it, advances its beneficial purpose, and construes doubt against the drafter. An instruction to contact a manager does not by itself necessarily exclude employees who themselves have managers above them. (Derived from Consolidated Freightways Corp. of Delaware v. Williams (1976).)