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King v. Trustees of Boston University

Supreme Judicial Court of Massachusetts
420 Mass. 52, 647 N.E.2d 1196 (1995)
ELI5:

Rule of Law:

A charitable pledge is an enforceable promise in Massachusetts if it is supported by either consideration or reasonable reliance by the charitable institution.


Facts:

  • In 1963, Boston University (BU), the alma mater of Dr. Martin Luther King, Jr., began seeking his papers for its special collections.
  • Concerned about the safety of his papers in the South during the volatile 1960s, Dr. King chose BU as a safe repository.
  • On July 16, 1964, Dr. King sent a letter to BU designating its library as the 'Repository' for his correspondence, manuscripts, and other papers.
  • The letter stated that all papers sent to BU would remain his 'legal property until otherwise indicated.'
  • The letter expressed Dr. King's intention to annually donate portions of the deposited materials to BU until all were given.
  • The letter concluded with the statement, 'In the event of my death, all such materials deposited with the University shall become from that date the absolute property of Boston University.'
  • Following the letter, Dr. King arranged for the removal and delivery of a significant volume of his papers into BU's custody.

Procedural Posture:

  • Coretta Scott King, as administratrix of Dr. Martin Luther King, Jr.'s estate, sued Boston University (BU) in a Massachusetts trial court for conversion to recover Dr. King's papers.
  • The case was tried before a jury on theories including charitable pledge and contract.
  • In response to special questions, the jury found that Dr. King had made an enforceable charitable pledge to BU supported by consideration or reliance, but that the letter was not a contract.
  • The trial court entered judgment for Boston University.
  • The plaintiff's motion for judgment notwithstanding the verdict or for a new trial was denied by the trial judge.
  • The plaintiff, Coretta Scott King, appealed the judgment, and the Supreme Judicial Court of Massachusetts granted her application for direct appellate review.

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Issue:

Does a letter stating an intention to make future gifts of personal property to a university, coupled with the delivery of that property into the university's custody, constitute an enforceable charitable pledge?


Opinions:

Majority - Abrams, J.

Yes. A letter expressing donative intent, combined with the act of placing the property in the charity's custody, can constitute an enforceable charitable pledge if supported by consideration or reliance. The court reasoned that to enforce a charitable pledge, Massachusetts law requires a promise and either consideration or reliance. The jury could reasonably find that Dr. King's letter, particularly the statement that all materials would become BU's property upon his death, constituted a binding promise, not just a statement of future intent. The creation of a bailment relationship—by delivering the papers into BU's custody—served as strong evidence of Dr. King's donative intent. Furthermore, the jury could find consideration or reliance in BU's actions, such as indexing the papers, making them available to researchers, providing trained staff, and holding a convocation, as these efforts went beyond the mere duties of a bailee exercising 'scrupulous care.'



Analysis:

This decision reinforces the traditional contract-law requirements for enforcing charitable pledges in Massachusetts, demanding either consideration or reliance. It explicitly distinguishes Massachusetts from the more liberal standard in the Restatement (Second) of Contracts § 90, which can permit enforcement of a pledge without consideration or reliance to prevent injustice. The court's focus on the bailment relationship as key evidence of donative intent provides a significant analytical framework for future cases involving pledges of tangible property. The ruling strengthens the position of charitable institutions seeking to enforce promises where they have taken possession of property and expended resources in reliance on the donor's pledge.

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