Case Facts
The original petitioner was Henry B. Ste. Marie. Ste. Marie died during the proceedings (pendente lite) and his executor, Shuey, was substituted — hence the caption of the case as it appears before the United States Supreme Court.
On 20 April 1865, the Secretary of War, Edwin M. Stanton, issued a public proclamation offering a reward of $25,000 for the apprehension of John H. Surratt, one of the alleged accomplices in the assassination of President Abraham Lincoln. The same proclamation additionally offered "liberal rewards" for any information that would conduce to Surratt's arrest. The offer was communicated to the public through official channels.
On 24 November 1865, the President — not the Secretary of War — caused to be published an order revoking the reward offered for the arrest of Surratt, pursuant to the authority conferred by statute.
In April 1866, several months after the revocation had been published, Ste. Marie — at that time serving as a soldier in the Papal military — communicated to the American minister at Rome, Mr King, that he had identified Surratt and that Surratt had confessed to him his participation in the plot against Lincoln's life. All of Ste. Marie's relevant acts therefore occurred after the revocation of the reward had already taken place. Both Ste. Marie and the American minister at Rome were ignorant of the revocation at the time of their first interview and at all subsequent times until Surratt's final capture.
Surratt was arrested at Veroli by the Papal government at the request of the United States on 6 November 1866, but escaped at the moment of leaving prison, crossed into Naples, and ultimately fled to Alexandria in Egypt, where he was re-arrested. The arrest was not made by Ste. Marie, either at Veroli or subsequently at Alexandria; his role was confined to the provision of information.
Congress subsequently passed an Act on 27 July 1868 (15 Stat. 234, s 3) under which $10,000 was paid to Ste. Marie in recognition of his services. The petition before the Court of Claims sought the remaining $15,000 balance of the original $25,000 reward. The Court of Claims dismissed the petition, finding that Ste. Marie's conduct amounted only to the provision of information conducive to an arrest, rather than an apprehension within the meaning of the proclamation, and that the $10,000 already paid constituted full and adequate satisfaction. The Supreme Court heard the case on appeal from that dismissal.
Held
The Supreme Court upheld the dismissal of the petition on two independent grounds.
First, the Court held that Ste. Marie had not effected the apprehension of Surratt and therefore could not claim the specific sum of $25,000 offered for that act. The discovery and ultimate arrest of Surratt were attributable entirely to the disclosures made by Ste. Marie to the American minister at Rome; however, factual causation did not suffice. The proclamation distinguished between two categories of entitlement: the specific sum of $25,000 for apprehension, and a "liberal reward" for information conducive to arrest. Ste. Marie's conduct fell within the latter category only. The $10,000 already paid to him under the Act of 27 July 1868 was accepted as constituting appropriate satisfaction for his informational services.
Second, and independently, the Court held that the offer of reward had been validly revoked by the President's proclamation of 24 November 1865, before Ste. Marie performed any of the acts upon which his claim was based. Because Ste. Marie first communicated with the American minister at Rome in April 1866 — after the revocation — no contract had come into existence between him and the United States. The fact that Ste. Marie was ignorant of the revocation was held to be immaterial.
Ratio Decidendi
The decision rests on two distinct legal propositions, both of which form the ratio of the case.
First, where a public offer of reward distinguishes between a specific sum for apprehension and a separate "liberal reward" for information, a claimant whose conduct extends only to the provision of information is entitled solely to the latter. Unless the claimant personally effected the arrest, or the arrest was made by his agents acting on his direction, he cannot claim the higher, specific sum designated for apprehension.
Second, a public offer of reward made by proclamation may be revoked before any rights have accrued under it, provided the revocation is communicated through the same public channel in which the offer was originally made. No binding contract arises under a public offer of reward until the offeree has performed the acts stipulated by the offer. Where the revocation is published through the same medium as the offer, it is effective as against the world regardless of whether any particular individual has actual notice of it. A claimant's ignorance of the withdrawal is wholly immaterial: the claimant who acts after revocation has been published through the appropriate channel acquires no rights under the original offer, however genuine his ignorance of that revocation may have been.
This principle is of particular significance in English contract law because it confirms the general rule — recognised in cases such as Byrne v Van Tienhoven (1880) and Dickinson v Dodds (1876) — that an offer may be withdrawn at any time before acceptance, and that communication of revocation may, in appropriate circumstances, be effected through means other than direct personal notice to the offeree. In the context of public offers of reward, the case establishes that publication through the same official channel suffices to constitute effective revocation, even where the individual claimant has no actual awareness of it.
Obiter Dicta
Not applicable.