Contracts I, Pages 169–179

Maryland National Bank v. United Jewish Appeal Federation of Greater Washington

Court of Appeals of Maryland, 1979


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.


Does a pledge to a charitable institution survive the death of the pledgor and become an enforceable obligation of his estate?


The Charitable Subscription Exception is not followed in Maryland.


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.


A charitable pledge is not enforceable in Maryland. Orphans' Court's order vacated.