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Mautner-Glick Corp. v. Dime Savings Bank of Williamsburgh

Citations: 232 A.D.2d 235; 647 N.Y.S.2d 782; 1996 N.Y. App. Div. LEXIS 10090

Court: Appellate Division of the Supreme Court of the State of New York; October 10, 1996; New York; State Appellate Court

Narrative Opinion Summary

In this case, the Supreme Court, New York County, ruled in favor of Dime Savings Bank by dismissing the action brought by brokers claiming entitlement to a commission. The brokers alleged that they were owed a commission for introducing buyers to Dime Savings Bank. However, the court found that the buyers did not execute the necessary agreement, thus failing to meet the criteria of being ready, willing, and able as required by established case law such as Lane—Real Estate Dept. Store v Lawlet Corp. Furthermore, the court noted that the brokerage agreement required specific conditions to be met for a commission to be earned, including the execution of an assignment agreement, which did not occur. The court also determined that the subsequent purchase of the property by the buyers at a foreclosure sale did not affect the commission claim. Additionally, the court dismissed the brokers' claims of economic duress and found the other arguments presented without merit. The decision was affirmed unanimously by the justices involved, ultimately resulting in no commission being awarded to the plaintiffs.

Legal Issues Addressed

Broker's Commission Entitlement

Application: The court determined that brokers are not entitled to a commission unless the buyers are ready, willing, and able, and the stipulated agreements are executed.

Reasoning: The court found that the plaintiffs, who were brokers, failed to establish their claim for earning a commission. The buyers introduced by the plaintiffs did not sign the agreement proposed by Dime, indicating they were not ready, willing, and able buyers.

Contractual Conditions for Commission

Application: The court enforced the brokerage agreement's requirement that commission is contingent upon execution of specific agreements and actual assignment.

Reasoning: The plaintiffs were bound by the brokerage agreement signed by their agent, which stipulated that commission entitlement was contingent upon the buyers executing the assignment agreement and the actual assignment occurring.

Effect of Foreclosure Sale on Commission Claims

Application: Participation in a foreclosure sale does not satisfy the conditions for commission entitlement under a brokerage agreement.

Reasoning: The fact that these buyers later won the property at a foreclosure sale was deemed irrelevant to the plaintiffs' claim.

Rejection of Economic Duress Claim

Application: The court found no merit in the plaintiffs' claim of economic duress in the context of the brokerage agreement.

Reasoning: The court also rejected the plaintiffs' assertion of economic duress and found their other arguments to be without merit.