Broadnax v. Ledbetter - 100 Tex. 375, 99 S.W. 1111 (1907)

Material Facts:

The defendant, Ledbetter, a local Sheriff, posted a notice that whoever captured and returned an escaped fugitive to the authorities would be rewarded $500. Broadnax captured the escaped fugitive and returned him to Ledbetter’s jail, Ledbetter, however, refused to give Broadnax the reward money and demurred that Broadnax did not allege he had knowledge of the notice of reward.

Procedural History:

At the trial court, Ledbetter’s demurrer was sustained and the petition was dismissed. Broadnax appealed the ruling, and the Court of Appeal certified the question to the Supreme Court of Texas.

Issues:

Whether or not Broadnax ought to have knowledge of the notice put out by Ledbetter before he (Broadnax) can recover the reward.

Holding:

It was held that knowledge of the notice was needed to recover the reward offered by Ledbetter.

Ratio Decidendi:

The court stated that a mere offer or promise to pay does not inherently give rise to a contract. Rather, a contract was deemed to arise only when an offer is accepted, either by performance or by words. The acceptor of an offer can only accept an offer if they know about its existence.

Comments:

What are your comments on the ruling?