St. Peter v. Pioneer Theatre Corp.

Pioneer Theatre Corp. (defendant) ran a "bank night" drawing that awarded a cash prize to entrants, including people simply standing outside the theatre, so long as they redeemed the prize within a limited time after their name was called. Mr. and Mrs. St. Peter entered and waited outside; a Pioneer employee told Mrs. St. Peter (plaintiff) her name was called, but the manager Parkinson clarified it was actually her husband's name, and as Mr. St. Peter approached to claim it, the theatre's lights went out, delaying him. When they found Parkinson again, he told Mr. St. Peter he was one second too late and refused to pay. Mr. St. Peter assigned his claim to his wife, who sued for breach of contract; the trial court directed a verdict for Pioneer, finding no consideration supported the offer.