King v. Trustees of Boston University

Brief Fact Summary. Plaintiff, wife of the late Martin Luther King, Jr., initiated this action to recover some of King’s papers from Defendant Boston University. King provided the papers and other items to Defendant along with a letter indicating that upon his death they would become the property of Defendant.

Synopsis of Rule of Law. Where there is donative intent and evidence that could support a finding of a promise supported by consideration or reliance, the case is properly submitted to the jury.

Facts. Defendant asked King if he would deposit some of his papers in its library’s newly expanded special collections. Several other universities approached King around the same time. Plaintiff testified that King thought the papers would be safest at Defendant’s library, but thought placing them there could subject him to criticism.
King deposited some of his papers with Defendant, but in a letter to Defendant, King indicated that the papers would remain his legal property unless otherwise indicated. Two statements from the letter are most important:
“All papers and other objects which thus pass into the custody of [BU] remain my legal property until otherwise indicated, according to the statements below.” Later the letter indicates that the papers will be transferred to Defendant in installments until all have been transferred.
“In the event of [King’s] death, all . . . materials deposited with [BU] shall become from that date the absolute property of [BU].”

Issue. Was the case properly submitted to the jury?

Held. Yes. The case was properly submitted to the jury.
If donative intent is clear, charitable subscriptions will be enforced according to the donor’s intent when specificity of the donor’s promise, consideration, and reasonableness of the charity’s reliance are considered.
The Court compares the first of the two statements provided above to a bailment situation. Defendant assumed a duty of care as set forth in the letter by accepting delivery of the papers. The Court found that the bailment presented sufficient evidence of donative intent for the question to go to a jury.
Plaintiff argues that the second statement is an attempt at a testamentary transfer, which fails to satisfy the statutory requirements of a will. The Court disagrees, finding that the statute of wills does not prevent a person from making a contract or promise that will not take effect until after death.
The Court also discusses possible sources of consideration. The Court notes that Defendant indexed the papers, made them available to researchers, and trained staff to care for the papers and assist researchers. In addition, the Court notes that some of Defendant’s actions may have gone beyond what was required for the bailment.
Because the Court finds evidence that could support a finding of a promise made enforceable by consideration or reliance, the Court holds that the case was properly submitted to the jury.

Discussion. In the present case, the Court determined that there was evidence that could support a finding of clear donative intent supported by consideration or reliance. Because there was sufficient evidence for such a finding, the case was properly submitted to the jury.