Denney v. Reppert
Court of Appeals of Kentucky, 1968.
432 S.W.2d 647.

Facts:
There was a bank robbery. Three police officers (Godby, Simms and Reppert) later apprehended them and recovered the stolen money. Prior to doing so, four employees of the bank (including Denney) gave the police officers all the information they had on the robbers that would be useful in catching them. There was a $500 reward for the arrest and conviction of each robber, thus a total of $1,500.

Issue:
Who is entitled to the money?

Holding:
Reppert.

Reasoning:
The bank employees were not entitled to anything because they were acting within the scope of their employment and performed a duty owed to the bank and public.

Similarly, the other two police officers were not entitled because it was their duty to apprehend the criminals.

Reppert, on the other hand, found a bit of a loophole:

  • He was sheriff deputy of Rockcastle County and the arrest took place in Pulaski County, therefore, he was not in his jurisdiction and was under no duty.

Rule:

“When a reward is to the general public for the performance of some specified act, such reward may be claimed by any person who performs such act, is the exception of agents, employees and public officials who are acting within the scope of their employment or official duties.”