Glover v. Jewish War Veterans of United States

District of Columbia Municipal Court of Appeals · Contracts

ContractsRewardsUnilateral ContractsAcceptanceprivate rewardcontract lawknowledge of offerintent to accept

Facts

After a pharmacist was murdered, Post No. 58 of the Jewish War Veterans offered a $500 reward to anyone furnishing information resulting in the apprehension and conviction of the killers, and notice of the reward was published in a newspaper. Police questioned Mary Glover on June 11 about the whereabouts of Reginald Wheeler, a suspect and the boyfriend of her daughter, and she gave them names and addresses of relatives her daughter might be visiting, including one in Ridge Spring, South Carolina. Officers first went to that location and arrested Wheeler there on June 13; Wheeler and another man were later convicted. Glover testified that she did not learn of the reward until June 12, after she had already given the police the information.

Issue

Is a person entitled to collect a privately offered reward for furnishing information leading to the arrest and conviction of a criminal when that person did not know of the reward offer at the time she gave the information?

Rule

For a reward offered by a private individual or organization, the offer is governed by contract law. There is no contract unless the claimant, at the time of giving the requested information or rendering the requested performance, knew of the reward offer and acted with the intention of accepting it.

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

In Phoenix, a neighborhood business alliance posted a $2,000 reward for information leading to the arrest and conviction of a warehouse burglar. Before seeing the posting, Elena Ruiz told detectives that her cousin had been staying at a motel in Mesa; the police arrested him there, and he was later convicted. Elena learned about the reward the next day and demanded payment.

Is Elena most likely entitled to recover the reward?

Explanation. A private reward is governed by contract law. Under the majority rule adopted here, there is no contract unless the claimant knew of the offer at the time of performance and acted with intent to accept it. Even though Elena's information caused the arrest and conviction, she acted in ignorance of the offer, so there was no acceptance and no mutual assent.