Webb v. McGowin

27 Ala. App. 82, 168 So. 199 · Alabama Court of Appeals · 1935

Contracts Assigned in 21 casebooks

Case brief summary

Rule

A person who freely promises to pay someone for a real benefit they already received, like being rescued from serious harm, can be legally held to that promise even though the help was given before any payment was promised.

Facts

Webb saved his boss from a falling block by steering it away himself, suffering serious injuries. The boss then promised lifelong payments, which continued for years until he died and stopped.

Procedural history

Webb sued the boss's estate for unpaid payments. The trial court dismissed his claim, so Webb accepted a dismissal to allow him to appeal to the Alabama Court of Appeals.

Issue

Can a promise to pay someone for past help be legally enforced when the promisor received a real, valuable benefit, like being saved from death or serious injury, even though the helper never asked for payment beforehand?

Holding

Yes. The court held that the promise to pay was a valid, enforceable contract because the boss received a real and valuable benefit, being saved from death or serious injury, and later promised to pay for it.

Reasoning

Saving someone from serious harm is a real benefit, like a doctor's service. A promise to pay for that benefit afterward is binding, especially since Webb was badly hurt doing it.

Opinions

Majority (Bricken): Held that a promise to pay for being saved from death or serious injury is enforceable because the rescuer gave a real, valuable benefit.

Concurrences (Samford): Agreed with the result, noting the legal rules were unclear but fairness and justice supported letting Webb recover.

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What did Joe Webb do that led to his injuries?

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