## Facts

- Three armed men robbed the First State Bank in Eubank, Kentucky, taking over $30,000.
- The Kentucky Bankers Association, through the bank’s membership, offered $500 “for the arrest and conviction of each bank robber,” totaling $1,500 for three robbers.
- The robbers were apprehended the same day by state police officers Garret Godby and Johnny Simms (acting in Pulaski County) with assistance from Tilford Reppert, a Rockcastle County deputy sheriff.
- Bank employees (including Murrell Denney and others) promptly provided descriptions and information to the public and officers to aid capture.
- Additional individuals claimed the reward, but some did not comply with the claim procedures specified in the reward offer.
- The Kentucky Bankers Association sought a court determination of entitlement to the reward due to competing claims.

## Issues

1. Whether bank employees who reported and provided information about the robbery could claim a reward for “arrest and conviction” when their actions were within their employment duties.
2. Whether on-duty law enforcement officers acting within their jurisdiction could claim a reward for apprehending criminals and recovering stolen money.
3. Whether a claimant who provided information but did not follow the reward’s claim procedures could recover.
4. Whether an out-of-county deputy sheriff assisting in an arrest outside his jurisdiction could claim the reward because he lacked a preexisting legal duty to act.

## Decision

- The Kentucky Court of Appeals affirmed the judgment awarding the entire $1,500 reward to Tilford Reppert alone.
- The bank employees’ claims were denied because their conduct was within the scope of their employment duties related to protecting the bank and responding to a robbery.
- The Pulaski County state police officers’ claims were denied because apprehending offenders within their jurisdiction was a preexisting public duty.
- Claims by certain citizen informants were denied where the claimants failed to satisfy the reward offer’s procedural conditions.
- Reppert was eligible because, acting outside his county jurisdiction, he had no legal duty to assist in the arrest and thus could accept the unilateral offer by performance.

## Legal Principles

- A reward offer is a unilateral contract that is accepted only by performance satisfying the offer’s stated conditions, including any procedural requirements for making a claim.
- Performance of a preexisting private duty (employee obligations) or preexisting public duty (on-duty officers acting within their jurisdiction) is not valid consideration to claim a reward for the same conduct.
- A public officer acting outside the scope of official duty or outside jurisdiction may be treated as a private actor for reward purposes and may recover if the offer’s conditions are met.

## Conclusion

The court held that the reward could be claimed only by a person who satisfied the reward’s conditions without merely performing a preexisting duty; because Reppert assisted in the arrest outside his jurisdiction and complied with the reward’s terms, he alone was entitled to the $1,500.


Denney v. Reppert, 432 S.W.2d 647 (Ky. Ct. App. 1968)