Facts
- Reverend Edward Pace was shot and killed at his home in Gadsden, Alabama, on November 26, 1973.
- In the days following the murder, The Gadsden Times published articles reporting that reward money was being offered for information leading to the arrest and conviction of those responsible.
- The Times reported on November 29 that Alabama’s governor had authorized a $1,000 reward for information leading to the killers’ arrest and conviction.
- That same day, if not earlier, Troy Gulledge provided information to law enforcement that later contributed to arrests and convictions in the case.
- After the arrests, the Times reported that unnamed private citizens had promised additional reward money, and that total reward “contributions” had grown to $8,000.
- The governor paid Gulledge the $1,000 reward he had officially offered.
- No additional reward money from the reported private pledges was paid to Gulledge.
- Gulledge sued The Gadsden Times under the pseudonym “John Doe,” alleging he acted in reliance on the reported total reward and that the Times was contractually obligated to pay him the remaining $7,000.
- The trial court denied the Times’ motion for a directed verdict. A jury found for Doe/Gulledge and awarded $7,000, and the Times appealed.
Issues
- Whether The Gadsden Times’ articles reporting reward money offered by the governor and unnamed citizens constituted a definite reward offer by the Times, creating a unilateral contract enforceable by Gulledge’s performance.
- Whether a reward may be recovered without proof that the claimant knew of the alleged offer and acted in response to it when providing the information.
- Whether the trial court erred by denying the Times’ motion for a directed verdict where the evidence did not support a finding that the Times was contractually bound to pay $7,000.
Decision
- The Alabama Court of Civil Appeals reversed and remanded.
- The court held the Times was not contractually bound to pay Gulledge $7,000.
- The court concluded the trial court should have granted the Times’ motion for a directed verdict because the evidence could not support a verdict imposing a reward obligation on the newspaper.
Legal Principles
- A reward is treated as a unilateral contract offer: acceptance occurs only by performing the requested act in response to the offer.
- To recover a reward, the claimant must have knowledge of the reward at the time the services are performed and must act in reliance on the offer.
- A newspaper’s reporting that others (such as government officials or private citizens) have offered or contributed reward money does not, without an express undertaking by the newspaper, constitute the newspaper’s own promise to pay.
- Contract liability requires proof of a definite offer and an intent by the alleged promisor to be bound; absent such proof, the claim should not go to the jury.
Conclusion
The court held that The Gadsden Times’ stories described reward offers and contributions attributed to the governor and private citizens, not a promise by the newspaper itself. Because a reward claim depends on a definite offer by the defendant and performance with knowledge of and in response to that offer, the evidence did not support holding the Times liable for $7,000, and the directed verdict should have been granted.