Bloomgarden v. Coyer
United States Court of Appeals, District of Columbia Circuit
479 F.2d 201 (D.C. Cir. 1973)
Henry Bloomgarden (plaintiff) was the president of Socio-Dynamics Industries, Inc. (SDI), a consulting and research firm. Coyer and Guy (defendants) were real estate developers seeking to develop a segment of the Georgetown waterfront in Washington, D.C. On January 26, 1970, Bloomgarden arranged for Coyer and Guy to meet one of Bloomgarden’s investors, David Carley, to discuss Coyer and Guy’s development plans. Bloomgarden arranged for the same group to meet with representatives of the Inland Steel Company on February 19, 1970, to discuss the same plan. At no point before either meeting did Bloomgarden indicate he expected a finder’s fee for these introductions. When asked what he hoped to obtain from the project after the second meeting, Bloomgarden only stated that he hoped SDI might gain work for the project. In April 1970, Coyer, Guy, and the Inland Steel Company reached an agreement regarding the development plan. In March 1970, Bloomgarden sought a finder’s fee on behalf of SDI. Upon realizing he could not bring suit on behalf of SDI, Bloomgarden sought a finder’s fee for himself in May 1970. Coyer and Guy refused, and Bloomgarden brought suit against them to recover a finder’s fee. The District Court granted Coyer and Guy summary judgment on grounds that Bloomgarden did not expect to be compensated for his services at the time that he rendered them.
Rule of Law
Holding and Reasoning (Robinson, J.)
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