Allegheny College v. National Chautauqua County Bank

Defendant promised to donate to plaintiff college, and they relied on her promise.

About 90% of college student receive student loans and grants. Some students receive endowed named scholarships from donors.

In the 1920s, Allegheny College conducted a fundraising drive.

In 1921, Ms. Johnston promised to have $5,000 out of her estate given to Allegheny College (College) (plaintiff) after her death in order to create the Mary Yates Johnston Memorial Fund. In 1923, she gave $1,000. In spite of this, in 1924, she repudiated her promised pledge.

May endowed named college scholarships from donors form the basis on an enforceable contract?

When a charitable subscription is made, and the charity relies on the promise, a promissory estoppel may result from the assumption of duty to apply the fund as a substitute for consideration.