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Quantum Realty, Inc. v. Lauderhill Apartment Investors, Ltd.

Citations: 391 So. 2d 228; 1980 Fla. App. LEXIS 18213Docket: No. 80-92

Court: District Court of Appeal of Florida; November 17, 1980; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellate court reviewed a decision concerning a real estate broker's entitlement to a commission for producing a ready, willing, and able buyer. Initially, the trial court denied the broker's commission due to a prospectus lacking information on existing mortgages and the buyer's offer being contingent upon the approval of the sellers' partners. The appellate court reversed this decision, clarifying that a broker earns a commission by fulfilling their contractual obligation of presenting a qualified buyer, regardless of subsequent seller-imposed conditions or contract specifics. The court highlighted that any issues regarding mortgages were resolved, and the seller's later withdrawal from the market, not the buyer's conditions, prevented the sale. Additionally, the requirement for the entire partnership's approval was only mentioned post-factum, after the buyer's presentation. Therefore, the appellate court instructed that judgment be entered in favor of the broker, affirming the right to a commission based on the established legal principle that sellers cannot retroactively introduce conditions to negate a broker's entitlement when the seller's actions disrupt the sale process.

Legal Issues Addressed

Broker's Commission and Seller's Responsibility

Application: The court emphasized that the broker should receive a commission if the seller is responsible for not finalizing the sale, even if the buyer meets the terms.

Reasoning: The court referenced multiple precedents, emphasizing that if the seller is responsible for not finalizing the sale, the broker should still receive their commission.

Entitlement to Broker Commission

Application: The appellate court held that a real estate broker is entitled to a commission upon producing a ready, willing, and able buyer, regardless of the employment contract specifics.

Reasoning: The appellate court disagreed with the trial court's findings and reversed the decision. It reiterated that a broker is entitled to a commission if they successfully produce a ready, willing, and able buyer, regardless of the specifics of the employment contract.

Introduction of Additional Conditions

Application: The need for confirmation from the entire partnership was introduced only after the broker presented a qualified buyer, which did not impede the broker's right to a commission.

Reasoning: The need for confirmation from the entire partnership was raised only after the buyer was presented.

Resolution of Sale Contingencies

Application: Concerns regarding existing mortgages did not negate the broker's commission as they were resolved between the buyer and seller, and the seller's withdrawal was the true cause of the sale's failure.

Reasoning: Any concerns regarding existing mortgages were resolved between the buyer and seller. The court pointed out that the seller's withdrawal from the market was the reason the sale did not go through.