Unilateral Contracts in the News: Found Dog Edition

My students think I hate unilateral contracts.  It’s not true.  I hate the statute of frauds and the parol evidence rule.  I’m fine with unilateral contracts.  They are interesting. They are also uncommon.  That is to say, they make up a tiny percentage of the universe of contracts.  That’s why they show up in the news.  

As reported in the New York Times, Daniel Sturridge, an English football (soccer) star, made a video after his dog, Lucci, a Pomeranian, disappeared from his Los Angeles home.  In the video, Mr. Sturridge offered a reward, “20 Gs, 30 Gs, whatever” to anybody who helped him to recover the dog.  Soon thereafter, Foster Washington, found the dog.  

Mr. Sturridge claims that he already paid Mr. Washington a reward.  On Tuesday, a judge found otherwise.  Mr. Sturridge now plays in Australia.  When he was signed as a striker with Liverpool in 2013, the contract was valued at $20 million.  Lucci is valued at $5300.  Mr. Washington has three children and makes $14/hour working as a security guard.  His utterance may have been too vague to be considered a clear offer.  Is it a promise to pay 20 G? 30? Whatever?  Is it an invitation to bargain?  Don’t care.  You are rich.  A poor man helped you out, thinking you would honor your pledge to provide a reward.

Pay the man.