Carr v. Mahaska County Bankers Ass'n
222 Iowa 411, 269 N.W. 494 (1936)
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Rule of Law:
An offer of a reward made to the public can only be revoked in the manner in which it was made or through a medium that provides the revocation with the same or similar publicity as the original offer.
Facts:
- The Mahaska County Bankers Association, an unincorporated group, created a poster offering a $1,000 reward for information leading to the arrest and conviction of anyone who robbed a member bank.
- Taintor Savings Bank, a member of the association, posted this reward offer in its bank lobby.
- Several years later, in December 1931 or January 1932, the cashier of Taintor Savings Bank removed the poster from the lobby and discarded it.
- The bank did not post any notice of revocation or otherwise publicly communicate that the reward offer was withdrawn.
- On January 10, 1935, another member bank, the Farmers Savings Bank of Leighton, was robbed.
- Plaintiffs provided information that led to the arrest and conviction of the robbers, having acted in reliance on the reward offer they believed to be active.
Procedural Posture:
- Plaintiffs brought an action at law against the Mahaska County Bankers Association and its member banks, including Taintor Savings Bank, in an Iowa trial court to recover the offered reward.
- The case was tried to the court without a jury.
- The trial court entered a judgment in favor of the plaintiffs for $1,000 against three defendant banks, including Taintor Savings Bank.
- Taintor Savings Bank (appellant) appealed the judgment to the Supreme Court of Iowa, with the plaintiffs as appellees.
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Issue:
Does the private removal of a publicly posted reward offer, without any public notification, constitute an effective revocation of that offer?
Opinions:
Majority - Richards, J.
No, the private removal of the poster did not constitute an effective revocation. An offer made to the public must be revoked with the same or like publicity as the offer itself. The court reasoned that private, uncommunicated acts, such as the cashier throwing the poster in a wastebasket, are insufficient to revoke a public offer because the public has no way of knowing about them. Citing Shuey v. U.S., the court affirmed the principle that revocation must be communicated through a similar medium as the offer. Furthermore, the court considered the purpose of the offer—to deter future crime—which implied that the offer was intended to be continuous. Therefore, the public could reasonably assume the offer remained in effect until a public revocation was made.
Analysis:
This case establishes a clear and objective standard for the revocation of public offers, particularly unilateral contracts like reward offers. It reinforces the 'equal publicity' doctrine, ensuring that the public is not misled by uncommunicated changes of intent by an offeror. The decision protects the reliance interests of the public, who may expend effort based on a publicly made promise. By focusing on the ongoing purpose of the offer (crime deterrence), the court also suggests that offers with a long-term objective are presumed to remain open until explicitly and publicly withdrawn, placing a higher burden on the offeror to communicate revocation effectively.
