Summary of Loring v. City of Boston
S. Ct. of Massachusetts, 1844

Relevant Facts: The mayor placed an ad in the newspaper offering a reward of first $500 then the next day $1000 for the conviction of people starting fires in Boston.  There was no letter of revocation the ad stopped running one week later. After a fire, Pl, declared intent to purse criminal defendant, Marriott, aiding in his arrest and conviction in order to gain the reward.  To this end the PL was successful.  However, the period from the running of the ad and the arrest was nearly four years.

Legal Issue(s): Whether an offer of reward continues to be in force into perpetutiy absent a notice or letter of revocation?

Court’s Holding: No

Procedure: Trial ct. UNCLEAR

Law or Rule(s):  The offer of a reward for the detection of an offender is an offer, on the part of the person making it, to all persons, which anyone, capable of performing, may accept at any time before it is revoked, and perform service, and thereby enter into a binding K.

Court Rationale: The advertisement was withdrawn and discontinued.  It could not be regarded as a perpetually continuing offer.  The offer was not an ordinance of the city, it is an act temporary in its nature, under exigent circumstances.  The object for the offer was to awaken the attention of authorities and the alarm of the arsonists.  The offer of reward was required to be kept in the mind of the public at large.  After a lapse of years, and after the publication of the offer has been long discontinued, it is notice to the public that the exigency had passed.  No contract existed founded on an alleged express promised can be maintained.

Plaintiff’s Argument: The city never published a time period limiting the offer’s terms, nor printed a revocation.

Defendant’s Argument: The offer was made four years prior, the ad was not run during that period and the emergency situation initiating the ad had ceased.