221 N.W.2d 609 (Iowa 1974)
Salsbury v. Northwestern Bell is a foundational modern case on the enforceability of charitable subscriptions.
Is a charitable subscription enforceable against the promisor in the absence of traditional consideration or proof that the promise induced action or forbearance by the charitable organization?
Under Iowa law, a charitable subscription is enforceable without proof of consideration or of action or forbearance in reliance on the promise. The court adopted Restatement (Second) of Contracts § 90(2): "A charitable subscription or a marriage settlement is binding without proof that the promise induced action or forbearance." More generally, promissory estoppel recognizes that a promise which the promisor should reasonably expect to induce action or forbearance and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement; however, for charitable subscriptions, proof of actual reliance is not required when the promise is definite and otherwise valid.
Yes. The charitable pledge is enforceable even without proof of consideration or reliance. The court adopted Restatement (Second) § 90(2) and directed enforcement of the defendant's written subscription.
Salsbury is a leading case on promissory estoppel and charitable subscriptions. It expressly adopts Restatement (Second) § 90(2), marking a clear shift from reliance‑based estoppel to a categorical enforceability rule for charitable pledges. For students, it illustrates how policy and institutional realities can generate carve‑outs from general contract doctrine and how courts may prefer transparent rules over doctrinal fictions. It also provides an important contrast with Allegheny College's consideration‑centric reasoning, offering multiple analytical pathways to enforcement on exams and in practice.