Shuey v. United States, 92 U.S. 73 (1875)

Material Facts:

The defendant, the United States, on 20th April made a public proclamation offering $25,000 as reward to anyone who apprehended a fugitive and a “liberal reward” to anyone who provided information leading to the apprehension of the fugitive. On 24th April, another public proclamation was made revoking the unilateral offer. The claimant, ignorant that the offer for reward was revoked, gave information that led to the arrest of the fugitive. The defendant gave $10,000 to the claimant but the claimant believed he is entitled to $15,000 extra, being the balance alleged to be due him of the reward of $25,000.

Procedural History:

At trial, the defendant was discharged from all liability. The claimant appealed the ruling.

Issues:

1. Whether or not Shuey is entitled to the full reward of $25,000.

2. Whether or not Sheuy’s ignorance of the revocation of the offer rendered the revocation invalid.

Holding:

1. Shuey is not entitled to the full reward of $25,000.

2. Sheuy’s ignorance of the revocation did not render the revocation invalid.

Ratio Decidendi:

The court stated that Sheuy did not meet the condition to receive the full $25,000 reward, as he did not apprehend the fugitive as stated in the proclamation. Justice Strong in delivering the opinion of the court stated that offers can “be withdrawn before rights had accrued under it; and it was withdrawn through the same channel in which it was made. The same notoriety was given to the revocation that was given to the offer”. It was ruled that the claimant should know that revocation can occur through the same channel the offer was made.