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Salsbury v. Northwestern Bell: Difference between revisions

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{{Infobox Case Brief
{{Infobox Case Brief
|court=Iowa Supreme Court
|court=Iowa Supreme Court
|date=September 18, 1974
|date=1974-9-18
|subject=Contracts/Outline
|subject=Contracts
|case_treatment=No
|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, [[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.
|rule=If the pledge contains no firm promise, only an intention to donate, then the pledge isn't contractually binding.
 
On the other hand, unconditional pledges are enforceable on the basis of public policy.
|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
|case_text_source=Quimbee video summary
|source_type=Video summary
|case_text_source=Quimbee
}}{{Infobox Case Brief/Case Text Link
}}{{Infobox Case Brief/Case Text Link
|link=https://casetext.com/case/salsbury-v-northwestern-bell-telephone-company
|link=https://casetext.com/case/salsbury-v-northwestern-bell-telephone-company

Latest revision as of 03:40, July 14, 2023

Salsbury v. Northwestern Bell
Court Iowa Supreme Court
Citation
Date decided 1974-9-18

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.

On the other hand, unconditional pledges are enforceable on the basis of public policy.

Case Text Links