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Salsbury v. Northwestern Bell: Difference between revisions
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Revision as of 13:45, June 30, 2023
Salsbury v. Northwestern Bell | |
Court | Iowa Supreme Court |
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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.