Brief Fact Summary. A lady was murdered and the governor offered an award to anyone who could provide information about the murder. Another lady provided information about the murder, but she did so prior to the award being offered.
Synopsis of Rule of Law. In this case "the manifest purpose of the statute was to elicit information not already available. It was not its purpose to provide recompense to one who had wholly performed before the offer was made."
Issue. Was there a valid acceptance of the governor's award?
Held. The court first observed the statute "authorizing the offer of a reward 'contain[s] the conditions of a contract.' " Further, "[s]o long as this offer continues in force it can be accepted only by compliance with its terms. This concept of an offer of a reward as an offer to enter into a contractual relationship which can be accepted by the performance of an act or series of acts is the one which has been generally accepted by the courts." The court then pointed to a point of contention between certain courts, "whether the performance must be with knowledge of the offer in mind, or in other words whether the person claiming the reward must act in response to the offer." The court further observed "where the public authorities have offered a reward for information leading to the apprehension and conviction of a criminal, some courts have held that even though the performance was begun before knowledge of the reward and completed afterwards, the person rendering the performance was entitled to recover." The court determined that the "facts of the instant case do not bring it within the comprehension of the rule generally accepted by the courts" especially since "the terms of the statute and the offer of the reward made pursuant to it are prospective." Additionally, "[t]he reward is for the person 'who shall give information leading to the arrest and conviction' of the guilty person. The manifest purpose of the statute was to elicit information not already available. It was not its purpose to provide recompense to one who had wholly performed before the offer was made."
Discussion. This case illustrates how an offer must be accepted in the realm of a reward offered by the government for information about a crime.