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Salsbury v. Northwestern Bell: Difference between revisions
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|issues=Is a charitable pledge enforceable without a demonstration of detrimental reliance (that is, [[Contracts/Consideration|consideration]])? | |issues=Is a charitable pledge enforceable without a demonstration of detrimental reliance (that is, [[Contracts/Consideration|consideration]])? | ||
|holding=Yes. Absent conditions placed upon the pledge, public policy supports enforcing charitable pledges as binding even without a showing of consideration or detrimental reliance. | |holding=Yes. Absent conditions placed upon the pledge, public policy supports enforcing charitable pledges as binding even without a showing of consideration or detrimental reliance. | ||
|rule=If the pledge contains no firm promise, only an intention to donate, then the pledge isn't contractually binding. | |||
|case_text_links={{Infobox Case Brief/Case Text Link | |case_text_links={{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/salsbury-v-northwestern-bell-telephone-co | |link=https://www.quimbee.com/cases/salsbury-v-northwestern-bell-telephone-co | ||
Revision as of 13:48, June 30, 2023
| Salsbury v. Northwestern Bell | |
| Court | Iowa Supreme Court |
|---|---|
| Citation | |
| Date decided | September 18, 1974 |
Facts
Salsbury (plaintiff) was a chairman of a now-defunct Charles City College in Iowa. He started a fundraising campaign that included a pledge drive.
Northwestern Bell ("Bell", defendant) was solicited for a donation. Bell's corporate board approved a pledge to donate to the aforesaid Iowa college.
Bell approved a $15,000 contribution pledge to the College to be paid in 3 installments over 3 years.
The College failed to operate.Procedural History
Salisbury sued Bell in an Iowa trial court claiming that the $15,000 pledge to the College was enforceable. Bell lost.
Issues
Is a charitable pledge enforceable without a demonstration of detrimental reliance (that is, consideration)?
Holding
Yes. Absent conditions placed upon the pledge, public policy supports enforcing charitable pledges as binding even without a showing of consideration or detrimental reliance.
Rule
If the pledge contains no firm promise, only an intention to donate, then the pledge isn't contractually binding.
