District of Columbia Municipal Court of Appeals - 68 A.2d 233
In the 1949 case Glover v. Jewish War Veterans of the United States, Post No. 58, the D.C. Municipal Court of Appeals confirmed a ruling in favor of the defendant - a non-governmental organization that had offered a reward for information resulting in the arrest and conviction of a local pharmacist's murderers. This case highlights the necessity of knowledge and intent for contract formation.
The court determined that the plaintiff, who provided information to the police leading to the capture of one murderer, was not eligible for the reward since she was unaware of the offer when she performed the act. The court dismissed her claim of accepting the offer through performance, as there was no mutual agreement between both parties. Additionally, the court applied the principle that a reward offer does not apply to cases where the claimant did not volunteer information but only gave it upon questioning by authorities
This case demonstrates that an offeror can limit the scope of an offer by specifying conditions or recipients, and that an offeree cannot accept an offer without knowledge of and intent to accept it. It also reveals that courts will not uphold contracts missing essential components, such as mutual consent or consideration.
The case concerns whether Mary Glover is entitled to a $500 reward offered by a non-governmental organization for providing information leading to the arrest and conviction of a murderer. The trial court ruled against her, stating that for a contract to exist in the context of reward offers, the claimant must have knowledge of the offer and intend to accept it. The court concluded that the law of contracts applies to questions regarding rewards offered by private individuals and organizations. The principle of mutual assent requires both parties to agree to the same terms, and without knowledge of the reward, there is no contract. The Restatement of the Law of Contracts and the majority of cases hold that knowledge of the reward is required for a contract to exist. In this case, the claimant did not volunteer information and did not claim to have knowledge of the reward, making the rule requiring knowledge of the reward particularly applicable. The lower court's decision was correct.
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