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Burnet Realty, Inc. v. Monson

Citations: 479 N.W.2d 432; 1992 Minn. App. LEXIS 16; 1992 WL 3380Docket: No. C7-91-1450

Court: Court of Appeals of Minnesota; January 13, 1992; Minnesota; State Appellate Court

Narrative Opinion Summary

In this case, Burnet Realty, Inc. sought to claim a commission from George R. Monson through an override agreement following the expiration of a real estate listing contract. The agreement stipulated that a 'protective list' of potential purchasers must be submitted within 72 hours post-contract expiration. Burnet Realty's agent had shown the property to the Brasilles, who later purchased the property, yet their names were omitted from the submitted list. The trial court ruled the list insufficient under Minnesota real estate regulations, which require potential purchasers' names to be included. Burnet Realty argued for substantial compliance, but the court found that the list, containing only the realtor's name, did not meet the statutory requirements, as it failed to inform the vendor of selling efforts. Consequently, the court dismissed claims for commission and unjust enrichment, affirming the necessity of purchaser identification on the protective list. The decision was upheld on appeal, confirming that Burnet Realty's list was fatally defective, resulting in no commission entitlement. Merrill Lynch Realty Operating Partnership, L.P. also entered the contract alongside the respondent, with Burnet Realty treated as its successor in this matter.

Legal Issues Addressed

Affirmation of Trial Court's Decision

Application: The appellate court affirmed the trial court's decision, finding the protective list fatally defective for lacking prospective purchasers' names.

Reasoning: The trial court's decision is affirmed as the protective list was found to be fatally defective under relevant rules.

Real Estate Commission under Override Agreements

Application: The court determined that a protective list within an override agreement must specifically include the names of potential purchasers to claim a commission.

Reasoning: The trial court ruled that a 'protective list' in a real estate override agreement is insufficient if it does not include the names of potential purchasers.

Statutory Interpretation under Minnesota Real Estate Regulations

Application: The court applied the literal language of Minnesota real estate regulations, requiring the protective list to contain prospective purchasers' names.

Reasoning: The definition of 'protective list' does not allow for the substitution of realtor names for prospective purchaser names, leading the trial court to find the protective list deficient.

Substantial Compliance in Contractual Obligations

Application: The court concluded that substantial compliance was not achieved because a list containing only a realtor's name failed to provide necessary information to the vendor.

Reasoning: The appellant contended that substantial compliance with the rules should be sufficient for recovery, necessitating a case-by-case analysis to assess the list's effectiveness.