## Facts

- A. L. Ledbetter was the elected sheriff of Dallas County, Texas, responsible for the custody of Holly Vann, a prisoner convicted of first-degree murder and sentenced to death.
- While Vann’s case was on appeal, Vann escaped from the Dallas County jail on January 25, 1905.
- After the escape, Ledbetter publicly offered a $500 reward to any person who recaptured Vann and returned him to custody in Dallas County or elsewhere in Texas.
- S. H. Broadnax recaptured Vann and returned him to custody, then demanded payment of the $500 reward.
- Ledbetter refused to pay.
- Broadnax’s petition did not allege that he knew of the reward offer at the time he recaptured and returned Vann.
- The trial court sustained Ledbetter’s demurrers for failure to state a cause of action and entered judgment for Ledbetter.
- On appeal, the intermediate appellate court certified to the Supreme Court of Texas a question on whether knowledge of the reward at the time of performance was required to recover.

## Issues

1. Whether a person may recover a publicly offered reward for performance of the requested act without alleging knowledge or notice of the reward offer at the time of performance.

## Decision

- The Supreme Court of Texas answered the certified question “yes”: knowledge or notice of the reward offer at the time of performance is essential to recovery.
- Because Broadnax did not plead that he knew of the reward when he recaptured Vann, his petition failed to state a claim for the reward.
- The court affirmed the judgment sustaining the demurrers and denying recovery.

## Legal Principles

- A reward offer is treated as a contractual offer; liability to pay is contractual rather than imposed solely because the act was performed.
- Acceptance of a reward offer by performance requires the claimant’s knowledge of the offer at the time the claimant performs the requested act.
- Performance that happens to match the terms of an unknown offer does not constitute acceptance because there is no assent to the offer.
- Public-policy arguments favoring rewards do not eliminate the requirement of knowledge, since rewards are intended to motivate conduct and cannot motivate an actor unaware of the offer.
- A plaintiff seeking a reward must plead facts showing entitlement to the reward, including knowledge of the offer when the services were rendered.

## Conclusion

The court held that a claimant cannot recover a publicly offered reward unless the claimant knew of the reward offer when performing the act, and it affirmed dismissal because the petition omitted that required allegation.


Broadnax v. Ledbetter, 100 Tex. 375, 99 S.W. 1111 (Tex. 1907)