Broadnax v. Ledbetter
99 S.W. 1111 (1907) (1907)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
To form a binding unilateral contract based on a reward offer, the person who performs the requested act must have had knowledge of the offer at the time of performance.
Facts:
- A. L. Ledbetter was the Sheriff of Dallas County, Texas.
- A prisoner named Holly Yann, who was convicted of murder, was in Ledbetter's custody.
- On January 25, 1905, Yann escaped from the Dallas County jail.
- After the escape, Ledbetter published a general public offer of a $500 reward to any party who would recapture Yann and return him to custody.
- Subsequent to the offer being made, S. H. Broadnax recaptured Yann.
- Broadnax returned Yann to the custody of Sheriff Ledbetter at the Dallas County jail, thereby fulfilling the conditions of the offer.
Procedural Posture:
- S. H. Broadnax (plaintiff) filed a petition against A. L. Ledbetter (defendant) in the County Court of Dallas County, Texas, to recover the $500 reward.
- Ledbetter filed demurrers, arguing the petition failed to state a cause of action because it did not allege Broadnax had knowledge of the reward offer when he captured the fugitive.
- The trial court sustained the demurrers and entered a judgment dismissing Broadnax's case.
- Broadnax appealed the dismissal to the Court of Civil Appeals for the Third District.
- The Court of Civil Appeals certified the legal question of whether knowledge of the reward was essential for recovery to the Supreme Court of Texas.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a person who performs the act for which a reward is offered entitled to recover the reward if they were unaware of the offer at the time of performance?
Opinions:
Majority - Williams, Associate Justice
No. A person who performs an act without knowledge of a reward offer is not entitled to recover the reward, because no contract is formed without mutual assent. Liability for a reward is created by contract, which requires a 'meeting of two minds'—an offer and an acceptance. One cannot accept an offer of which they are ignorant. Performing the specified acts without knowledge of the offer is not an acceptance because the performance is not made in reference to the offer. The value of the service to the offerer is irrelevant; the legal obligation arises because the offerer's promise induced the other party to act. Without this inducement, there is no mutual assent and thus no enforceable contract.
Analysis:
This decision solidifies the contract law principle that acceptance of a unilateral offer requires knowledge of the offer and an intent to accept. It firmly rejects the minority view that a reward is a 'boon' or 'gratuity' paid for a beneficial service regardless of the performer's knowledge. By grounding the right to a reward in traditional contract doctrine, the court establishes a clear precedent that one cannot accidentally accept an offer. This holding impacts all unilateral contract scenarios, requiring plaintiffs to demonstrate they were aware of and acted upon the offer to create a binding agreement.
Unlock the full brief for Broadnax v. Ledbetter