Salsbury v. Northwestern Bell

Salsbury (plaintiff) was a chairman of a now-defunct Charles City College in Iowa. He started a fundraising campaign that included a pledge drive.

Northwestern Bell ("Bell", defendant) was solicited for a donation. Bell's corporate board approved a pledge to donate to the aforesaid Iowa college.

Bell approved a $15,000 contribution pledge to the College to be paid in 3 installments over 3 years.

The College failed to operate.

Salisbury sued Bell in an Iowa trial court claiming that the $15,000 pledge to the College was enforceable. Bell lost.

Is a charitable pledge enforceable without a demonstration of detrimental reliance (that is, consideration)?

Yes. Absent conditions placed upon the pledge, public policy supports enforcing charitable pledges as binding even without a showing of consideration or detrimental reliance.

If the pledge contains no firm promise, only an intention to donate, then the pledge isn't contractually binding.

On the other hand, unconditional pledges are enforceable on the basis of public policy.