A man was murdered. D offered a reward of $500 to anyone who furnished information resulting in the apprehension and conviction of the murderer.
Police received information that one of the murderers was Reginald Wheeler, boyfriend of P's daughter.
Police interviewed P about the whereabouts of her daughter. P gave them info about their relatives. Police found P's daughter and Wheeler with the help of P's information. Wheeler was later convicted.
P first learned of the reward the day after she offered the information to the police.
P sued D to pay the reward.
Procedural History:
Lower court found for D, no contract.
DC COA affirmed, found for D, no contract.
Issues:
Can a party assent to an offer (requesting acceptance through performance only) without the knowledge of its existence?
Holding/Rule:
It is impossible for an offeree to assent to an offer unless he knows of its existence.
Reasoning:
There can be no contract unless the claimant when giving the desired information knew of the offer of the reward and acted with the intention of accepting such offer; otherwise, they gave the information not in the expectation of receiving a reward but rather out of a sense of public duty or other motive not connected with the reward.
It is impossible that there should be an acceptance unless the offeree knows of the existence of the offer.
A offers a reward for information leading to the arrest and conviction of a criminal. B, in ignorance of the offer, gives information leading to his arrest and later, with knowledge of the offer and intent to accept it, gives other information necessary for conviction. There is no contract.
The only exception is for gov't bodies since the gov't is benefitted equally whether or not the claimant gives the information with knowledge of the reward .
