221 N.W. 2d 609 (Iowa 1974).
One-Sentence Takeaway: A charitable pledge is enforceable based on public policy grounds alone without any showing of consideration or detrimental reliance.
Summary: Defendant, a telephone company, sent a letter to the solicitor for the charity in aid of a funding drive to establish a local college, which failed shortly thereafter. The letter declared that the contribution of $15,000 would be made over a 3-year period in three equal payments. The college assigned the pledge to a supplier of the college and gave the supplier the unsigned pledge card to reflect Defendant’s donation.
The college was later closed and Salsbury, the chairman of the board of trustees for the college, sued Defendant to recover the pledged amount.
The court held that an unequivocal pledge or subscription to a charitable organization should be binding without proof of consideration or detrimental reliance, as a matter of public policy.