52 was a contracts case tried in the Massachusetts Supreme Judicial Court in 1995, involving gratuitous transfer and consideration.

[1] The trial court ruled in favor of the defendant, the papers were deposited as a charitable contribution to Boston University.

[2] Martin Luther King Jr., an alumnus of Boston University, was asked in 1963 to deposit some papers in their library's newly expanded special collections.

The letter contained two important statements: "In accordance with this action I have authorized the removal of most of the above-mentioned papers and other objects to Boston University, including most correspondence through 1961, at once.

The letter was not a contract between the parties because there was no indication of bargained for exchange to bound Dr. King to his promise.