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
- 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.