Loring v. City of Boston
48 Mass. 409 (1844) (1844)
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Rule of Law:
An offer of a reward made to the public, which does not state a specific time limit for acceptance, is not a perpetual offer and terminates after a reasonable period of time has passed. What constitutes a reasonable time is a question of law determined by the circumstances of the case.
Facts:
- On March 26, 1837, the City of Boston published an advertisement offering a reward of $500, which was increased to $1,000 the next day.
- The reward was offered for the detection and conviction of any person who set fire to buildings within the city.
- This offer was made in response to a special emergency, as several alarming fires had recently occurred.
- The reward advertisement did not contain any time limit or expiration date.
- The city discontinued the publication of the advertisement after a short period.
- In January 1841, three years and eight months after the offer was published, the plaintiffs arrested an arsonist named Marriott.
- Following the arrest, the plaintiffs prosecuted Marriott until he was convicted of the crime.
- The plaintiffs then demanded the $1,000 reward from the city, claiming they had accepted the offer.
Procedural Posture:
- The plaintiffs brought an action against the City of Boston in a Massachusetts court to recover the offered reward money.
- The case was presented to the Supreme Judicial Court of Massachusetts for a decision on the legal question of whether a contract was formed.
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Issue:
Does a public offer of a reward, made without an explicit time limit in response to a specific emergency, remain a continuing offer that can be accepted nearly four years after it was first published?
Opinions:
Majority - Shaw, C. J.
No. A public reward offer made without a specific time limit does not remain open indefinitely and terminates after a reasonable amount of time. The court reasoned that an offer of a reward is a unilateral contract proposal that becomes a binding contract only upon performance of the service requested. When an offer contains no express time limit, the law implies a 'reasonable time' for acceptance. Here, the offer was made in response to a specific, temporary emergency. Its purpose was to stimulate public vigilance during that crisis. After three years and eight months, and the long-discontinued publication, the offer could not be considered a continuing motivation for the public. It must be presumed to have been forgotten and was no longer in effect when the plaintiffs acted. Therefore, the offer had ceased before the plaintiffs performed the service, and no contract was formed.
Analysis:
This case establishes a foundational principle in contract law regarding the duration of unilateral offers made to the public. By implying a 'reasonable time' limitation on offers lacking an explicit expiration date, the court prevents such offers from remaining open in perpetuity, which would create indefinite liability for offerors. This decision gives courts the authority to determine what constitutes a reasonable time on a case-by-case basis, considering the offer's purpose and circumstances. It underscores that the context in which an offer is made is critical to interpreting its terms, particularly its duration.
