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Law School Case Brief

Stephens v. Memphis - 565 S.W.2d 213 (Tenn. Ct. App. 1977)

Rule:

He who is the active and efficient cause in securing the result described in an offer of reward is the one entitled to it. He is the one who accomplishes the result, who brings it about. A reward offered for information leading to the arrest and conviction of an offender is earned by the person who first communicates the information that ultimately leads to both. In order to become entitled to the reward, a claimant must be the first person to give information to the proper authorities and the information must be effective in leading to the arrest and conviction of the offender.

Facts:

Plaintiff Charles Quitman Stephens brought suit in Tennessee state court against defendant City of Memphis and others seeking to recover rewards offered by them for information leading to the arrest and conviction of the murderer of Dr. Martin Luther King, Jr. Dr. King was shot to death from ambush at the Loraine Motel in Memphis, Tennessee, on April 4, 1968. The Chancellor denied recovery on two grounds: (1) Stephens gave the Memphis Police practically all the material information he had on the evening of April 4, 1968, immediately after the death of Dr. King and before the rewards had been offered, and; (2) information furnished by Stephens did not lead to the identification and arrest of James Earl Ray as the murderer. Stephens' suit was dismissed, and he appealed.

Issue:

Was Stephens entitled to the reward offered for any information that led to the arrest of the person who murdered Dr. King?

Answer:

No.

Conclusion:

The court affirmed the judgment of the chancery court. The court found that Stephens' contention that the chancellor erred in finding him a recalcitrant witness was not supported by the record. There was no evidence that such a finding was made by the chancellor. Stephens would have been a material witness but not an indispensable witness if the murderer had pleaded not guilty and it had been necessary to go to trial. Knowledge of an offer of reward at the time of giving information was a prerequisite to recovery. An examination of the various statements made by Stephens and contained in the record together with his testimony reflected that he gave the police all the information he had before the rewards were offered. Further, the evidence showed that the information furnished by Stephens did not lead to the identification and arrest of the murderer as required for the rewards. Fingerprints and laundry marks did. The information furnished by Stephens before the rewards were offered only led to the conviction of the murderer.

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