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Blanton v. Friedberg

United States Court of Appeals for the Fourth Circuit
819 F.2d 489 (4th Cir. 1987)


Facts

In separate agreements, Richard Friedberg (defendant) hired Eugene Blanton (plaintiff) to develop two tracts of land that Friedberg owned. Blanton was to be paid in a variety of ways including commissions for the sale of property in the developments and for the sale of timber from one of the developments, consulting fees, percentages of gross rents from property tenants, and Blanton’s expenses. For both projects, Blanton expended significant time and money toward their completion. Before the completion of either project, however, Friedberg fired Blanton. Blanton brought suit for breach of contract and, because Friedberg claimed that no contract existed, for quantum meruit. Blanton sought to recover for his expenses and for his services rendered, for which he had yet to be fully compensated. At trial, Friedberg claimed that most of the development of the properties came after Blanton was fired. Friedberg also claimed that he had paid certain of Blanton’s claimed commissions to other realtors after Blanton was fired, thus reducing what may be allocated to Blanton. The jury found in favor of Blanton. Based on Blanton’s anticipated commissions and fees, the jury awarded Blanton $394,525 for quantum meruit. Friedberg appealed.

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Holding and Reasoning (Hall, J.)

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