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Procedural Posture

Procedural Posture

Defendant studio challenged a judgment from the Superior Court of Los Angeles County (California), which found in favor of plaintiff former employee in the employee’s action for breach of an employment contract.

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Overview

The employee entered a contract with the studio to immediately dispose of household goods and personal effects in New York and move to California to become general manager of the studio based on specific compensation. In his action against the studio, the employee alleged that there was a balance due him for services rendered, for damages for the remainder of the term of his employment, and for the studio to buy him a house and give him stock, as per an oral promise. The jury found in favor of the employee. On appeal, the studio argued that the statute of frauds prevented enforcement of the oral agreement and the evidence of any such agreement should not have been admitted. The court found that the oral agreement was an admission and was properly admitted to show the terms of the oral agreement. However, it was impossible to determine whether the verdict was based on the theory of estoppel or on the implied promise to pay for services rendered. Because the evidence was insufficient to establish an estoppel, the award of interest could not be upheld.

Outcome

The court modified the judgment by only paying the employee for services rendered or owed and by reversing the award for interest and for reliance damages. The court ordered that if the employee did not accept the judgment as modified and dismiss the causes of action, the judgment would be reversed in its entirety.

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