Tuesday, December 28, 2021
Unilateral Contracts in the News: Found Dog Edition
My students think I hate unilateral contracts. It's not true. I hate the statute of frauds and the parol evidence rule. I'm fine with unilateral contracts. They are interesting. They are also uncommon. That is to say, they make up a tiny percentage of the universe of contracts. That's why they show up in the news.
As reported in the New York Times, Daniel Sturridge, an English football (soccer) star, made a video after his dog, Lucci, a Pomeranian, disappeared from his Los Angeles home. In the video, Mr. Sturridge offered a reward, "20 Gs, 30 Gs, whatever" to anybody who helped him to recover the dog. Soon thereafter, Foster Washington, found the dog.
Mr. Sturridge claims that he already paid Mr. Washington a reward. On Tuesday, a judge found otherwise. Mr. Sturridge now plays in Australia. When he was signed as a striker with Liverpool in 2013, the contract was valued at $20 million. Lucci is valued at $5300. Mr. Washington has three children and makes $14/hour working as a security guard. His utterance may have been too vague to be considered a clear offer. Is it a promise to pay 20 G? 30? Whatever? Is it an invitation to bargain? Don't care. You are rich. A poor man helped you out, thinking you would honor your pledge to provide a reward.
Pay the man.
Jeremy, much as I love dog reward cases against wealthy owners, I must dissent from t your belief that unilateral contracts are rare and atypical, even though it was propounded by no less an authority as Llewellyn. If a ‘unilateral contract’ is defined as a contract in which only one of the two parties ever makes a promise or has a duty to perform, then they are by far the most common form of contract. Blog post to follow.
Posted by: Sidney DeLong | Dec 28, 2021 2:13:59 PM