Bloomgarden v. Coyer
United States Court of Appeals, District of Columbia Circuit
479 F.2d 201 (D.C. Cir. 1973)
Bloomgarden (plaintiff) introduced real estate developers Coyer and Guy (defendants) to potential partners for a Georgetown waterfront project, never mentioning a finder's fee before or during either introduction and, when asked about his interest, saying he only hoped his firm might get future work on the project. Only after the developers reached a deal with one of the introduced parties did Bloomgarden seek a finder's fee, first for his company and then for himself; the developers refused, and Bloomgarden sued. The district court granted the developers summary judgment on the ground that Bloomgarden had not expected compensation when he rendered the introductions.
Whether restitution damages for services rendered are available when the services were rendered without an expectation of payment and the benefiting party could not reasonably have believed payment was expected.