Glover v. Jewish War Veterans of United States
68 A.2d 233 (1949)
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Rule of Law:
A person is not entitled to collect a reward from a private organization if they provided the requested information without prior knowledge of the reward offer, as a valid contract requires the offeree to know of the offer and act in acceptance of it.
Facts:
- On June 5, 1946, Maurice L. Bernstein was murdered.
- The following day, June 6, the Jewish War Veterans of the United States (Post No. 58) publicly offered a $500 reward for information resulting in the apprehension and conviction of the murderer.
- Notice of the reward was first published in a newspaper on June 7.
- Police identified Reginald Wheeler as a suspect and learned he was the boyfriend of Mary Glover's daughter.
- On the evening of June 11, police officers visited and questioned Mary Glover at her home.
- In response to police questioning, Glover provided names and addresses of relatives her daughter and Wheeler might be visiting, including one in Ridge Spring, South Carolina.
- On June 12, the day after giving the information to the police, Glover first learned that a reward had been offered.
- Based on the information Glover provided, police arrested Wheeler in South Carolina on June 13, and he was subsequently convicted.
Procedural Posture:
- Mary Glover filed a lawsuit against the Jewish War Veterans of the United States in the trial court to collect the reward.
- At the conclusion of the trial, the judge instructed the jury to return a verdict for the defendant.
- The trial court entered a judgment in favor of the defendant based on the directed verdict.
- Mary Glover, as the claimant-appellant, appealed the judgment to the present appellate court.
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Issue:
Does a person who provides information leading to an arrest, without knowledge that a private organization has offered a reward for such information, have a legal right to collect that reward?
Opinions:
Majority - Clagett, Associate Judge.
No. A person who gives information without knowledge of a reward offer cannot form a contract and is therefore not entitled to the reward. The court reasoned that rewards offered by private organizations are governed by contract law, which requires mutual assent—an offer and an acceptance. For an acceptance to be valid, the offeree must know that an offer exists. In this case, Glover provided the information not in response to the offer, but out of a sense of public duty or for other motives. The court explicitly adopted the rule articulated by Professor Williston and the Restatement of Contracts, stating that it is impossible for an offeree to assent to an offer without knowledge of its existence. Therefore, no contract was formed between Glover and the Jewish War Veterans.
Analysis:
This decision solidifies the application of traditional contract law principles to unilateral offers, such as private rewards. It establishes in this jurisdiction that performance of the requested act is not, by itself, sufficient to constitute acceptance. The performer must also have knowledge of the offer and act with the intent to accept it, reinforcing the concept of 'meeting of the minds' as essential for contract formation. The case distinguishes private rewards from government rewards, where some courts have allowed recovery on public policy grounds, thereby narrowing the path to recovery for claimants who act without knowledge in the private sphere.
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