Maglica v. Maglica

Anthony Maglica (defendant) started a machine shop business in 1955. In 1971, Maglica met Claire Halasz (Halasz) (plaintiff) and they began living together, holding themselves out as husband and wife, and building the business together. In addition, Halasz changed her name to Maglica. In 1974, Maglica incorporated the business and placed all of the business shares under his name. In 1978, Halasz developed a successful flashlight and soon the business was worth hundreds of millions of dollars. In 1992, Halasz learned that Maglica was transferring the stock to Maglica’s children rather than to Halasz and Halasz sued Maglica for breach of contract and quantum meruit. At trial, the judge gave instructions on the measure of recovery for a quantum meruit claim, stating that the reasonable value of Halasz’s services was either the value of the cost to obtain similar services or the value of the benefit to Maglica. The trial judge also gave jury instructions on the issue of the existence of an implied-in-fact contract to share ownership of the business, stating that the fact that Maglica and Halasz lived together and held themselves out to be married should not be considered in the determination. The jury awarded Halasz $84 million. Maglica appealed the award and Halasz cross-appealed the jury instructions regarding the existence of an implied-in-fact contract.