Glover v. Jewish War Veterans of United States

Brief Fact Summary. Plaintiff, Mary Glover, brought suit, regarding her entitlement to a reward that had been offered by Defendant, Jewish War Veterans of the United States, after she gave police information leading to the arrest and conviction of an individual who had murdered a Jewish Pharmacist.

Synopsis of Rule of Law. There is no contract and thus no acceptance of an offer of reward if an individual gives desired information, without the intention of accepting such an offer.

Facts. On June 5, 1946, Maurice Bernstein, a pharmacist, was murdered. The Defendant, the Jewish War Veterans of the United States (Defendant), offered a $500 reward to anyone offering information that lead to the arrest and conviction of the person(s) guilty of murdering Bernstein. The Plaintiff, Mary Glover (Plaintiff), pointed the police to Reginald Wheeler (Wheeler), the boyfriend of her daughter, who was later convicted of the crime.
After Plaintiff had turned Wheeler over to the police, she realized that Defendant had offered a reward, and sought to claim it. By her own admission, Plaintiff stated she did not realize a reward had been offered until two days after she went to the police and gave them the desired information; however, she brought suit against Defendant under the theory that they had made an offer that she had accepted by performance. The Trial Court instructed the jury to rule for the Defendants and the Plaintiff appealed.

Issue. This case presents the issue as to whether an offeree can accept an offer, if he or she does not know of its existence.

Held. Affirmed.
The Court held that it is impossible for an offeree to accept an offer that he or she does not know about. Particularly, in this case, Plaintiff offered information to the police without knowing that a reward had been offered. Therefore, she could not later claim the reward under the theory that she had accepted it by performance.

Discussion. Mutual assent must be had by both the offeror and the offeree. An offeree cannot assent to an agreement after he or she has already performed, thereby binding an offeror who may not intend to be bound.