Raden v. Laurie

In 1948 actress Piper Laurie (defendant), who was a minor, and her mother entered into two contracts with Ted Raden (plaintiff). Under the first contract, Raden was required to try to find offers of employment for Laurie and to serve as her manager. However, under the second contract, executed in July, Raden was only required to advise and counsel Laurie in business matters, in financial arrangements with her employers, and in her choice of a personal agent. Although Raden was no longer required to find employment for Laurie under the second agreement, Laurie’s obligation to pay Raden a commission of 10 percent on Laurie’s engagements was retained. In 1949, when Laurie ended the relationship, Raden sued for commissions in the amount of $3,100 that Raden alleged were due to him from money Laurie earned from engagements. Laurie responded that Raden had never found employment for her. Laurie asserted that although Raden took her to places where she might find work, these efforts did not yield employment. Raden countered that when he took Laurie to places, he was only trying to aid Laurie’s development and instruction. Raden also pointed out that under the second agreement, he was not required to find employment for Laurie. Raden did not possess an agent’s license as was required for those who manage artists. Laurie moved for summary judgment. A trial court ruled in Laurie’s favor. According to Laurie, the court’s favorable ruling was on the basis that Raden was an agent or a manager for artists without a license. Section 1650 of the California Labor Code stated that one is not a manager for an artist unless one both provides advice and counsel and secures or attempts to secure employment offers for the artist pursuant to a contract with the artist. Raden appealed.