## Facts

- In 1837, after repeated arsons in Boston, the mayor caused newspaper advertisements to be published for about a week offering a city-paid reward for the apprehension and conviction of any person who set fire to a building in the city.
- The reward was initially stated as $500 and was soon increased by a later advertisement to $1,000 on similar terms.
- The advertisements ceased after roughly a week.
- About three years and eight months later, the plaintiffs apprehended a suspected arsonist in connection with an extensive city fire, procured witnesses, and secured the suspect’s conviction for arson.
- Plaintiffs demanded payment of the $1,000 reward; the City of Boston refused, asserting the offer was no longer in force.

## Issues

1. Whether the city’s published reward advertisement constituted a binding offer capable of acceptance by performance.
2. Whether the reward offer remained open nearly four years after publication, or instead was impliedly limited to a reasonable time that had expired.
3. Whether the determination of “reasonable time” under the proved circumstances was for the court as a matter of law.

## Decision

- The Supreme Judicial Court of Massachusetts granted the city’s motion for nonsuit.
- The court treated the reward advertisement as creating a contractual obligation if its terms were performed while the offer remained operative.
- The court held the offer was not indefinite in duration; it was impliedly limited to a reasonable time.
- As a matter of law, performance three years and eight months after publication was beyond a reasonable time, so the offer had lapsed before plaintiffs acted.
- The court rejected the argument that any obligation ended with the mayor’s term, recognizing the municipality’s continuing corporate existence.

## Legal Principles

- A public reward offer can form a unilateral contract, binding the offeror to pay upon full performance, provided the offer is still open when performance occurs.
- Unless the offer specifies otherwise, a reward offer is construed as limited to a reasonable time rather than continuing indefinitely until formally withdrawn.
- When the relevant facts and circumstances are established, what constitutes a reasonable time for acceptance or performance may be decided by the court as a question of law.
- Municipal obligations do not automatically terminate with changes in individual officers; the municipality acts as a continuing corporate entity.

## Conclusion

The court held that Boston’s published reward offer, though capable of creating a binding obligation upon performance, was impliedly limited to a reasonable time and had lapsed well before plaintiffs performed nearly four years later, requiring dismissal of the claim for the reward.


Loring v. City of Boston, 7 Metc. 409 (Mass. 1844)