Glover v. Veterans

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Glover v. Veterans
Court DC Court of Appeals
Citation 68 A.2d 233
Date decided August 10, 1949

Facts

Maurice Bernstein was murdered on June 5th 1946.

  • Jewish War Veterans of the United States of America = JWV = "Veterans" = defendant

Veterans offered a $500 reward for anyone provide information leading to the arrest & conviction of Bernstein's killer.

1 of the suspects was the boyfriend of Mrs. Glover's daughter. Mrs. Glover told the police that her daughter & the suspect boyfriend, Wheeler, had left the city.

Wheeler was subsequently convicted of Bernstein's murder after the police used Mrs. Glover's tips.

The reward was first published on June 7th 1946. However, Mrs. Glover first learned about the reward on June 12th 1946.

Procedural History

Glover sued the Veterans seeking to collect the $500 reward. Glover lost.

Glover appealed to the District of Columbia Municipal Court of Appeals.

Issues

Can an offeree [Glover] create a binding contract by performance when the offeree [Glover] has no knowledge of the offer [reward]?

Holding

No. An offeree can't create a binding contract by performance when the offeree has no knowledge of the offer.

Reasons

Judge Clagett: Rewards offered by private organizations are governed by contract law.

An offeree can't assent to an offer unless the offeree knows the offer exists. Otherwise, there is no meeting of the minds.

Rule

Comments

The DC police also declined to pay a reward to Glover.

Resources