## Facts

- Consolidated Freightways posted a notice at its Fulton County terminal offering an “up to $5,000” reward for information leading to the arrest and conviction of anyone stealing or concealing company freight or property.
- The notice stated information would be confidential and instructed employees to call the company security office or contact a supervisor or terminal manager.
- Williams, a dock foreman/supervisor employed at the terminal, read the notice and suspected a co-employee of theft.
- Williams arranged coverage for his regular duties and conducted surveillance by hiding in a trailer to observe the suspect.
- Williams’s actions produced information that led to the co-employee’s arrest and conviction for theft of company property.
- Williams demanded payment of the reward; the company refused.
- Williams sued to recover the reward as a contractual obligation, and a jury awarded him $5,000.
- The trial court denied the company’s motions for directed verdict and entered judgment on the verdict; the company appealed.

## Issues

1. Whether the posted reward was an offer open to acceptance by supervisors or was limited to non-supervisory employees.
2. Whether Williams supplied consideration and accepted the reward offer, or merely performed pre-existing employment duties.
3. Whether the phrase “up to $5,000” was too indefinite to be enforced as a contractual promise.
4. Whether Williams’s claim failed because he allegedly was not thinking about the reward when he acted, despite knowing of the posted offer.
5. Whether the evidence required a directed verdict for the employer rather than submission to the jury.

## Decision

- The Court of Appeals of Georgia affirmed the judgment for Williams.
- The court held the notice was a valid unilateral offer to employees generally, including supervisors.
- The court held there was evidence that Williams’s conduct exceeded his ordinary job duties, permitting a finding of consideration and acceptance by performance.
- The court rejected indefiniteness, treating “up to $5,000” as a maximum amount within which the factfinder could set the award; the $5,000 verdict was allowed to stand.
- The court held Williams’s motive or whether the reward was foremost in his mind did not bar recovery where he knew of the offer and performed the requested act.
- The trial court properly denied the employer’s motions for directed verdict because the case presented jury questions on the disputed elements.

## Legal Principles

- A publicly posted reward may constitute an enforceable unilateral contract offer when it invites performance and is directed to a sufficiently broad class of potential offerees.
- Contract interpretation favors a construction that sustains the agreement as a whole; language should be read in context rather than used to carve out exclusions inconsistent with the overall text.
- Performance may constitute consideration for a reward where the claimant’s actions go beyond pre-existing employment obligations; whether conduct exceeds ordinary duties can be a fact question.
- A reward stated as “up to” a specified sum can be sufficiently definite when it sets a ceiling and allows the factfinder to determine an amount within that limit.
- For acceptance of a unilateral contract, knowledge of the offer and completion of the requested performance is sufficient; the performer’s subjective motive is not dispositive.

## Conclusion

The court enforced the employer’s posted reward as a unilateral contract and upheld a jury award to a supervisor who, with knowledge of the offer, undertook actions beyond his normal duties that led to the arrest and conviction of a company thief, rejecting defenses based on offeree scope, pre-existing duty, indefiniteness, and claimed lack of reward-focused intent.


Consolidated Freightways Corp. of Del. v. Williams, 139 Ga. App. 302, 228 S.E.2d 230 (Ga. Ct. App. 1976)