## Facts

- A theater operated a promotional “Bank Night” drawing in which names were drawn from a free registration book for a cash prize advertised as $275.
- Registration was open to anyone, whether or not the person purchased admission; the winner had to claim the prize within a short stated time after being called.
- On the night in question, an employee told Ruth St. Peter outside the theater that her name had been called as the winner.
- St. Peter promptly entered the theater and demanded the $275; the manager stated that the name drawn was her husband’s, not hers.
- St. Peter signaled her husband to come forward; during a brief period when the lights went out and the manager was not immediately located, the manager later told the husband he was “one second too late” under the time limit.
- The husband assigned any claim to the prize to St. Peter, who sued the theater and its manager to recover the $275.

## Issues

1. Whether the Bank Night promotion created an enforceable unilateral contract supported by consideration, permitting the prize winner (or assignee) to sue for the advertised prize.
2. Whether the theater could rely on a strict time-limit condition to deny payment when the delay was caused by the theater’s agent announcing the wrong name.
3. Whether the prize promise was unenforceable as an illegal lottery or contrary to public policy.

## Decision

- The Iowa Supreme Court reversed the directed verdict for the defendants and remanded.
- The court held the promotion created an enforceable unilateral contract; the required acts of registering and being present/available to claim constituted sufficient consideration.
- The court rejected an illegality defense, treating the promotion as not a prohibited lottery under Iowa law.
- The court held the defendants were estopped from invoking the time limit where their agent’s mistaken announcement caused the delay in presenting the actual winner.

## Legal Principles

- A publicly advertised prize offer may constitute a unilateral offer that becomes binding upon performance of the stated conditions.
- Consideration for a unilateral contract may consist of non-monetary acts requested by the promisor that impose legal detriment on the promisee and confer practical benefit on the promisor (e.g., registration and required presence).
- A party may be estopped from asserting a contractual condition when that party, through its agent, causes the other party’s noncompliance with the condition.
- A promotional contest is not void for illegality where the governing law treats the scheme as non-lottery and lawful; a lawful promotion may support a civil contract claim.

## Conclusion

The court held the theater’s Bank Night promotion was a binding unilateral contract supported by consideration and that the theater could not defeat recovery by enforcing a time-limit condition made impossible to meet due to its own agent’s misannouncement; the directed verdict for the defendants was therefore reversed and the case remanded.


St. Peter v. Pioneer Theatre Corp., 227 Iowa 1391, 291 N.W. 164 (Iowa 1940)