Wood Bros. Homes, Inc. v. Walker Adjustment Bureau
Colorado Supreme Court
601 P.2d 1369 (1979)
Fred Gagnon, a California resident, agreed to perform carpentry work for Wood Bros. Homes, Inc. (Wood) (defendant), a Delaware corporation with its principal place of business in Colorado. The agreement was signed in Colorado; the work was to be performed in New Mexico. After Gagnon began work, he was shut down by authorities because he lacked a New Mexico contractor’s license. The failure to procure a license required by the New Mexico Construction Industries Licensing Act (N.M. Licensing Act) triggered a potential criminal sanction and denial of the right to seek legal recovery for work performed. Wood cancelled the contract with Gagnon and refused to pay him for the work performed. Walker Adjustment Bureau (Walker) (plaintiff), acting as Gagnon’s assignee, sued Wood in a Colorado court for its failure to pay Gagnon. Walker sought recovery on the basis of breach of contract or, in the alternative, quantum meruit. Applying New Mexico law, the trial court granted summary judgment to Wood. The court of appeals held that Colorado law applied and reversed. The court of appeals reasoned that if it followed the approach of the Restatement (Second) of Conflict of Laws (Second Restatement), Colorado would have the most significant relationship to the contract because of its interest that agreements be validated and that the parties’ expectations be protected. The court of appeals also held that Wood was estopped from arguing that Gagnon was unlicensed because Wood indicated that Gagnon could work in New Mexico despite knowing that he was not licensed. The Colorado Supreme Court granted Wood’s petition for certiorari.
Rule of Law
Holding and Reasoning (Hodges, C.J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 170,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.