It is usually so clear that no rights can arise out of acts done without knowledge of or intent to accept an offer, though such acts might be an appropriate means of acceptance if intended for that purpose, that few questions ever arise thereunder. One class of cases is, however, anomalous in its treatment by some courts and has given rise to a conflict of authority on this point. This class consists of cases where a reward has been offered for doing some act and the act has been done in ignorance of the offer. The logical treatment of these cases would be to hold that no acceptance can be made of an uncommunicated offer, and many courts do, in fact, so hold.1 Many of these cases are cases where a reward was offered of the choice of the shipper. Cincin-nati, New Orleans & Texas Pacific Ry.

Rankin, 241 U. S. 319, 60 L. ed. 1022.

4 Adams Express Co. v. Croninger, 226 U. S. 491, 57 L. ed. 314, 44 L. R. A. (N.S.) 257.

5 Central, of Georgia, R. R. v. Lipp-man, 110 Ga. 665, 50 L. R. A. 673, 36 S. E. 202.

1 California. Hewitt v. Anderson, 56 Cal. 476, 38 Am. Rep. 65.

Connecticut. Marvin v. Treat, 37 Conn. 96, 0 Am. Rep. 307;

Illinois. Williams v. West Chicago Street Railroad Co., 191 III. 610, 85 Am. St. Rep. 278, 61 N. E. 456; Chicago, etc., Ry. Co. v. Sebring, 16 111. App. 181; Ensminger v. Horn, 70 111. App. 605; Board of Trustees of Police Pension Fund v. Railway Ticket Pro-tective Bureau, 175 111. App. 464.

Kentucky. Lee v. Flemingsburg, 37 Ky. (7 Dana) 29 [overruled in Auditor v. Ballard, 72 Ky. (9 Bush.) 572, 15 Am. Rep. 728].

for the arrest of an alleged criminal.2 Other courts moved rather by a feeling that if the person offering the reward receives the benefit of the act, he should make compensation, than by technical legal considerations have treated such acts as a valid acceptance, and have enforced such contracts.3 Many of these cases are cases where a reward was offered for the recovery of property.4 In some cases of rewards for the arrest of criminals, the party who made the arrest recovered the reward, even where the arrest was made before the reward was offered.5 This principle has been applied to rewards offered under statutory authority.6 He has been allowed to recover where he had heard of the reward, though he had not seen the formal notice until after the arrest.7

The questions of whether any proper acceptance is made where the offer is communicated, but the act is done for a motive other than the reward, and whether any consideration exists are questions discussed later.8

Mississippi. Fidelity and Deposit Co. v. Messer, 112 Miss. 267, 72 So. 1004.

Missouri. Smith v. Vernon County, 188 Mo. 501, 87 S. W. 949.

New York. Fitch v. Snedaker, 38 N. Y. 248, 97 Am. Dec. 791; Howland v. Lounds, 51 N. Y. 604, 10 Am. Rep. 654.

North Dakota. Couch v. State, 14 N. D. 361, 103 N. W. 942.

Tennessee. Stamper v. Temple, 25 Tenn. (6 Hump.) 113, 44 Am. Dec. 296.

Texas. Broadnax v. Ledbetter, 100 Tex. 375, 9 L. R. A. (N..S) 1057, 99 8. W. 1111.

2 Illinois. Ensminger v. Horn, 70.

App. 605; Lee v. Flemingsburg, 37 Ky. (7 Dana) 29.

Mississippi. Fidelity & Deposit Co. v. Messer, 112 Miss. 267, 72 So. 1004.

New York. Fitch v. Snedaker, 38 N. Y. 248, 97 Am. Dec. 791.

Tennessee. Stamper v. Temple, 25 Tenn. (6 Hump.) 113, 44 Am. Dec. 296.

Texas. Broadnax v. Ledbetter, 100 Tex. 375, 9 L. R. A. (N.S.) 1057, 99 S. W. 1111.

Recovery of a reward offered for lost property was refused in Howland v. Lounds, 51 N. Y. 604, 10 Am. Rep. 654.

3 England. Gibbons v. Proctor, 64 L. T. R. 594.

Delaware. Eagle v. Smith, 4 Houst. (Del.) 293.

Indiana. Board v. Wood, 39 Ind. 345; Board of Commissioners v. Davis, 162 Ind. 60, 64 L. R. A. 780, 69 N. E. 680; Sullivan v. Phillips, 178 Ind. 164, 98 N. E. 868; Everman v. Hyman, 26 Ind. 1pp. 165, 84 Am. St. Rep. 284, 28 N. E. 1022; Dawkins v. Sappington, 26 Ind. 199.

Kentucky. Auditor v. Ballard, 72 Ky. (9 Bush) 572, 15 Am. Rep. 728.

Massachusetts. Wentworth v. Day, 44 Mass. (3 Met.) 352, 37 Am. Dec. 145.

Vermont. Russell v. Stewart, 44 Vt. 170.

4 Eagle v. Smith, 4 Houst. (Del.) 293; Dawkins v. Sappington, 26 Ind. 109; Sullivan v. Phillips, 178 Ind. 164, 98 N. E. 868; Everman v. Hyman, 26 Ind. App. 165, 28 N. E. 1022, 84 Am. St. Rep. 284.

5 Coffey v. Commonwealth (Ky.), 37 S. W. 575; Auditor v. Ballard 72 Ky. (9 Bush), 572, 15 Am. Rep. 728; Smith v. State, 38 Nev. 477, L. R. A. 1916A, 1276, 151 Ac. 512.

6 Smith v. State, 38 Nev. 477, L. R. A. 1916A, 1276, 151 Ac. 512.

7 Swanton v. Ost, 74 111. App. 281.

8 See Sec. 150 et seq. and Sec. 526.

It is sufficient if the essential act called for by the reward, is done with knowledge of such reward, whatever preliminary work may have been done without such knowledge.9 A offered a reward for the return of a lost article. B found the article before the reward was offered; and returned it after such reward was offered, learning that A was the owner only upon seeing the offer of reward. B's act is a sufficient acceptance of such offer under either theory.10