Salsbury v. Northwestern Bell Telephone Co. explained

Salsbury v. Northwestern Bell Telephone Co.
Court:Iowa Supreme Court
Full Name:John Salsbury, Appellee, v. Northwestern Bell Telephone Company, Appellant.
Date Decided:September 18, 1974
Citations:221 N.W.2d 609, 1974 Iowa Sup. LEXIS 1120
Judges:David Harris, Don LeGrand, W. W. Reynoldson
Plaintiff:John Salsbury
Defendant:Northwestern Bell Telephone Co.
Decision By:David Harris

Salsbury v. Northwestern Bell Telephone Co., 221 N.W.2d 609 (IA 1974), was a case decided by the Iowa Supreme Court concerning contract law.

Background

When John Salsbury was helping to establish Charles City College, Northwestern Bell agreed to make a $5,000 contribution for the next three years but only made one payment. The school sued for breach of contract but the telephone company maintained the contract was unenforceable because they received no consideration for the donations.

Decision

The court adopted the position of the Restatement of Contracts, Second that charitable subscriptions can be enforced even without consideration or detrimental reliance.[1]

Notes and References

  1. Ayres, I. & Speidel R.E. Studies in Contract Law, Seventh Edition. Foundation Press, New York, NY: 2008, p. 141