Denney v. Reppert

Brief Fact Summary.

Three armed men entered First State Bank (Bank) to rob it, and each robber had an outstanding reward offered by the Bank of $500 for their arrest and conviction.  The robbers were apprehended and convicted, and many claimants sought the reward. 

Synopsis of Rule of Law.

When a reward is offered to the general public for the performance of some specified act, such reward may be claimed by any person who performs such act, with the exception of agents, employees and public officials acting within the scope of their employment or public duties.  

Facts.

The total outstanding reward of $1500 was sought by four employees of the Bank, citizens who gave information to the arresting officers, two arresting officers of Pulaski County (where the crime took place), and Tilford Reppert, an arresting officer and sheriff from another county.  All of the claimants were named as defendants, and the lower court held that only Tilford Reppert was entitled to the money.

Issue.

Which of the claimants were entitled to the award for information leading to the apprehension of the bank robbers?

Held.

Affirmed.  Tilford Reppert was entitled to the $1,500 reward, as he was acting outside the scope of his jurisdiction when he assisted with the arrest. 

·         The bank employees were not entitled to the reward because they were acting within the scope of their employment and were under a duty to protect the bank’s resources.

·         The informants gave valuable information to the officers, but were not entitled to the money because they did not follow the procedure as set forth in the reward offer.

·         The two arresting officers from Pulaski County were not entitled to the reward because they were acting within the scope of their employment.  

Dissent.

None.

Concurrence.

None.

Discussion.

Only Tilford Reppert was entitled to the reward because assisted in the arrest and was not under any duty to do so.  However, the court gave great commendation to the bank employees who acted bravely to assist their community.