Gadsden Times v. Doe

345 So. 2d 1361 · Court of Civil Appeals of Alabama · 1977

Facts

Reverend Edward Pace was shot and killed at his home in Gadsden, Alabama. The Gadsden Times published articles about a reward for information leading to the conviction of his slayers, attributing the reward to citizens, the city commission, or the mayor. Troy Gulledge provided information to the police, naming a suspect, Ronnie Battles, on a Wednesday or Thursday, before December 1. Gulledge knew of a reward generally before providing this information. Police used Gulledge's information to issue arrest warrants and arrest suspects on December 1 and 2. Gulledge received a state reward but sought an additional $7,000 mentioned in the Times articles. City officials and Times employees denied knowledge of this specific reward fund. When the Times failed to pay, Gulledge sued.

Procedural history

Troy Gulledge, as John Doe, brought an action in the lower court against The Gadsden Times. A jury verdict required the Times to pay Gulledge $7,000. The Times' motion for a new trial was denied, leading to this appeal by The Gadsden Times.

Issue

Was The Gadsden Times contractually bound to pay Troy Gulledge $7,000 as a reward for information he provided?

Holding

No, The Gadsden Times was not contractually bound to pay Gulledge the $7,000 reward. The court reverses the lower court's judgment and remands the case.

Rule

The obligation to pay a reward rests exclusively on a contract, which requires an offer and acceptance. In Alabama, one must have knowledge of the reward offer at the time of performing the services for which the reward is offered to be entitled to it. Gulledge acted before the Times published any article that could be construed as an offer from the Times itself, and the earlier articles attributed the reward to other parties. Therefore, no contract existed between Gulledge and the Times.

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