Maryland National Bank v. United Jewish Appeal Federation of Greater Washington
Facts:
Polinger pledged $200,000 to the plaintiff for the year of 1975. He died at the end of 1976, with $133,500 unpaid on his pledge. Defendant was his estates personal representatives, and disallowed the claim for the balance of the pledge.
Procedural History:
The Orphans' Court granted plaintiff's motion for summary judgment and denied plaintiff's motion for the same.
Issue:
Does a pledge to a charitable institution survive the death of the pledgor and become an enforceable obligation of his estate?
Rule:
The Charitable Subscription Exception is not followed in Maryland.
Reasoning:
As Maryland does not follow the Charitable Subscription Exception, consideration would be required. As this was a gratuitous promise, there was no consideration and hence it was not enforceable.
Holding:
A charitable pledge is not enforceable in Maryland. Orphans' Court's order vacated.