## Facts

- A private veterans’ organization publicly offered a $500 reward for information resulting in the apprehension and conviction of those guilty of a pharmacist’s murder.
- Police questioned Mary Glover about the whereabouts of her daughter and her daughter’s boyfriend, Reginald Wheeler, a suspected participant in the murder.
- On June 11, Glover told police her daughter and Wheeler had left Washington, D.C., and provided names and addresses of relatives where they might be located, including an address in Ridge Spring, South Carolina.
- Police went to the Ridge Spring address and arrested Wheeler on June 13 while he was with Glover’s daughter.
- Wheeler and another suspect were later convicted of the murder.
- Glover testified she did not know about the reward when she provided the information; she learned of it the next day. Her husband corroborated that no one mentioned a reward during the police interview and that they learned of it later from the newspaper.
- Glover demanded payment of the reward; the organization refused, and the trial court directed a verdict for the organization. Glover appealed.

## Issues

1. Whether a person can accept a private reward offer by performance when the person provided the requested information without knowledge of the reward at the time of performance.
2. Whether, under ordinary contract principles, a unilateral reward offer creates liability when the requested act is performed but not in reliance on the offer.

## Decision

- The appellate court affirmed the directed verdict for the organization.
- The court held Glover was not entitled to the reward because she provided the information without knowledge of the reward offer and therefore could not have accepted it.
- The court treated the published reward as a unilateral offer governed by general contract law for private reward offers.
- Because acceptance of an offer requires knowledge of the offer’s existence, performance done without such knowledge does not form a contract.

## Legal Principles

- A privately offered reward is analyzed as a unilateral contract offer under general contract doctrine.
- An offeree cannot accept an offer without knowledge of its existence; mutual assent requires informed assent.
- The requested act constitutes consideration only if performed in response to (and with the intent to accept) the reward offer; later learning of the offer does not convert prior performance into acceptance.
- Moral motives or public-spirited conduct do not substitute for contractual assent in claims for privately offered rewards.
- Authorities involving governmental rewards may rest on different policy or statutory grounds and do not control private reward disputes governed by ordinary contract rules.

## Conclusion

Because Glover provided the information leading to Wheeler’s arrest without knowing of the private reward offer, her conduct could not constitute acceptance of the offer, and no enforceable contract to pay the reward was formed.


Glover v. Jewish War Veterans of U.S., Post No. 58, 68 A.2d 233 (D.C. 1949)