In Glover v. Jewish War Veterans of the United States, Post No. 58, the Municipal Court of Appeals for the District of Columbia ruled in 1949 that a person who supplies information leading to a criminal’s arrest cannot collect a privately offered reward if they did not know the reward existed when they acted. The decision is a staple of first-year contracts courses because it applies the mutual-assent requirement to a sympathetic claimant and denies recovery anyway.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
The Murder, the Reward, and Mary Glover’s Tip
Maurice L. Bernstein, a Washington, D.C. pharmacist, was murdered on June 5, 1946. The next day, Post No. 58 of the Jewish War Veterans of the United States offered a $500 reward “to the person or persons furnishing information resulting in the apprehension and conviction of the persons guilty of the murder of Maurice L. Bernstein.” Newspapers received the notice on June 6 and published it on June 7.2Occidental College. Glover v. Jewish War Veterans of United States
Two men were later identified as responsible: Jesse James Patton, arrested about a day after the reward was published, and Reginald Wheeler, who was the boyfriend of Mary Glover’s daughter and remained at large.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
On the evening of June 11, 1946, police visited Glover at her home to ask about Wheeler. She told them her daughter and Wheeler had left the city on the day of the murder, and she gave them the names and addresses of relatives, including one in Ridge Spring, South Carolina. Two days later, officers traveled there and arrested Wheeler in the company of Glover’s daughter. Both Wheeler and Patton were convicted.2Occidental College. Glover v. Jewish War Veterans of United States
When Glover sought the $500, the timing sank her claim. She testified that she did not learn of the reward until June 12, the day after she spoke with police. Her husband testified he had not known about it during the interview either, and only heard about it two or three days later.2Occidental College. Glover v. Jewish War Veterans of United States
What the Court Held
The court, deciding the appeal on August 10, 1949, affirmed a directed verdict for the Jewish War Veterans.3vLex. Glover v. Jewish War Veterans of United States, 68 A.2d 233 A reward offer, the court explained, is a contract offer, and contract formation requires mutual assent. Because Glover did not know the offer existed when she gave police the information, she could not have intended to accept it, and no contract was formed. Whatever motivated her, a sense of public duty or something more personal, it was not acceptance of a bargain she had never heard of.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
The Authorities Behind the Rule
The opinion rested on two leading contract sources. It quoted Samuel Williston’s treatise for the proposition that “it is impossible for an offeree actually to assent to an offer unless he knows of its existence,” and cited the American Law Institute’s Restatement of the Law of Contracts, which used a nearly identical hypothetical: a reward is offered for information leading to an arrest, someone supplies the information without knowing of the reward, and no contract results.4OpenCasebook. Glover v. Jewish War Veterans of United States
The court also pointed to a long line of state decisions reaching the same result, from Texas, New York, Illinois, California, Kansas, Mississippi, and Arkansas. Among them was Broadnax v. Ledbetter, a 1907 Texas Supreme Court case on the same question.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
One boundary matters here. The court distinguished private rewards from government-offered rewards, noting that the “great weight of authority” required proof of knowledge and intent to accept only when the reward came from a private party. The rule announced in Glover speaks to private rewards.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
Why the Case Is Still Taught
The facts do the teaching. Glover really did provide the information that led to an arrest and conviction. She acted in good faith. Her tip was exactly what the reward asked for. The court denied her claim anyway, for a reason unrelated to the quality of what she did: she did not know about the reward when she did it. The distance between moral desert and legal entitlement is what makes the case such a durable illustration of the principle that contract formation requires mutual assent, not just matching conduct.1Casemine. Glover v. Jewish War Veterans of United States, 68 A.2d 233
Where the Rule Stands Today
The knowledge requirement in Glover remains the majority rule for private reward offers in the United States. The Restatement (Second) of Contracts added a partial exception at Section 51: someone who starts performing the requested act without knowledge of the offer, then learns of it before finishing, can accept by completing the performance.5ContractsCasebook.org. Offer and Acceptance III – Unilateral Contracts That exception would not have saved Glover. Her performance was already complete before she heard about the reward.
Courts have carved narrower exceptions in specific contexts. In Anderson v. Douglas and Lomason Co. (1995), the Iowa Supreme Court held that an employee does not need to have read or known about an employee handbook’s specific promises in order to enforce them, reasoning that a knowledge requirement would create an inequitable divide between employees who happened to read the handbook and those who did not.6Justia. Anderson v. Douglas and Lomason Co., 540 N.W.2d 277 That departure was tied to the employment context and did not disturb the general rule for reward offers. For an ordinary private reward, the principle from Glover still governs: you cannot accept an offer you do not know exists.