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Salsbury v. Northwestern Bell

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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)?

Case Text Links