Gadsden Times v. Doe

345 So. 2d 1361 (1977)

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Gadsden Times v. Doe

Alabama Court of Civil Appeals
345 So. 2d 1361 (1977)

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Facts

Unknown persons murdered a minister in Gadsden, Alabama, on November 26, 1973. On November 29, the Gadsden Times newspaper (the Times) (defendant) reported that Alabama’s governor had offered a reward of $1,000 for information that would lead to the killers’ arrest. That same day, if not earlier, Troy Gulledge (plaintiff) tipped off the police to key information that eventually cracked the case and led to the arrest and subsequent conviction of several suspects. In announcing these arrests on December 2, the Times reported that unnamed private citizens had supplemented the governor’s reward offer by promising additional rewards totaling $7,000. The governor made good on his promise and paid Gulledge $1,000. However, when no one else stepped forward with reward money, Gulledge, identifying himself only as “John Doe,” sued the Times to collect the balance. Gulledge alleged that he had acted in reliance on receiving the $8,000 in rewards that the Times reported and that the Times had breached a contractual obligation by failing to pay $7,000 of that money. After the trial court denied the Times’ motion for a directed verdict, the jury found the Times in breach of contract and awarded Gulledge $7,000. The Times appealed to the Alabama Court of Civil Appeals.

Rule of Law

Issue

Holding and Reasoning (Holmes, J.)

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