Sparks v. Fidelity National Title Insurance Company
United States Court of Appeals for the First Circuit
294 F.3d 259 (2002)
Relevant factsFree
Broker Sparks (plaintiff) found interested buyers for Fidelity's (defendant) subdivision but never obtained a signed purchase contract from any of them before his listing agreements expired, after which Fidelity separately sold the property to a different buyer Sparks never introduced; the trial court granted Fidelity summary judgment on Sparks's commission claim.
IssueFree
Whether, in some jurisdictions, earning a commission requires closing a binding sales contract, not just procuring a buyer.