O'Hara v. J. W. Rex Co.

17 Pa. D. & C.2d 191, 1958 Pa. Dist. & Cnty. Dec. LEXIS 58
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedMarch 27, 1958
Docketno. 98
StatusPublished

This text of 17 Pa. D. & C.2d 191 (O'Hara v. J. W. Rex Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Hara v. J. W. Rex Co., 17 Pa. D. & C.2d 191, 1958 Pa. Dist. & Cnty. Dec. LEXIS 58 (Pa. Super. Ct. 1958).

Opinion

Dannehower, P. J.,

Defendant has filed preliminary objections to plaintiff’s complaint in assumpsit to recover contingent compensation for services rendered upon two alleged oral contracts in procuring contracts with the United States Government for the manufacture of shot and shell. These objections were argued before the court en banc and are now pending for decision.

The complaint alleges that J. Walter Rex, president and authorized agent of defendant corporation, which was engaged in the manufacture of shot and shell, orally engaged the services of plaintiff, who had many years of experience and know-how in handling bids and contracts with the United States Government, to secure Government contracts for the manufacture of shot and shell, that plaintiff performed such services and as a result, defendant became the successful low bidder on a certain Government contract awarded to defendant on June 21, 1951, that in April 1951, J. W. Rex orally agreed to compensate plaintiff at the rate [192]*192of $.65 per shot, or a total of $6,045, that defendant paid $1,300 on account and has refused to pay the balance.

Plaintiff further alleges that at a later date, J. W. Rex orally agreed to retain the services of plaintiff on a second and larger Government contract and orally agreed, if successful, to employ plaintiff as secretary of defendant corporation at a yearly salary of $25,000 with an expense account of $18,000 yearly, that on August 14, 1952, defendant was awarded the second contract, it being the lowest bidder, that defendant, on October 10, 1952, informed plaintiff that it would not employ him as agreed and that the fair and reasonable value of said services is $.35 per shot for 71,940 shots manufactured, or compensation on the second contract of $25,179.

Defendant’s preliminary objections in the nature of an application for a more specific complaint as to the dates, terms, place of the alleged oral contracts and whether plaintiff is suing for agreed commissions or on a quantum meruit are without merit. It is sufficient to say that a careful reading of the complaint does state the dates and terms and clearly implies that the alleged oral agreements were made at defendant’s principal office at Lansdale, Montgomery County. Furthermore, concerning the compensation on the second contract, the position as secretary with defendant corporation, if plaintiff fully performed his services, he may recover on a quantum méruit basis, because the compensation was not a liquidated amount. See A. L. I. Restatement of the Law of Contracts, §350.

The principal and important question in this case is raised by defendant’s preliminary objection in the nature of a demurrer alleging that each oral contract is for fees and commissions made contingent upon the procurement of a contract with the United States Gov[193]*193ernment and is, therefore, void and unenforceable because contrary to public policy and is in violation of section 5 of title 2 of executive order no. 9001, “prohibiting contingent agreements for compensation”.

This executive order, promulgated on December 27, 1941, and amended several times, reads in part:

“Every contract entered into pursuant to this order shall contain a warranty by the contractor in substantially the following terms:

“The contractor warrants that he has not employed any person to solicit or secure this contract upon any agreement for a commission, percentage, brokerage, or contingent fee. Breach of this warranty shall give the government the right to annul the contract or, in its discretion, to deduct from the contract price or consideration the amount of such commission, percentage, brokerage, or contingent fees. This warranty shall not apply to commissions payable by contractors upon contracts or sales secured or made by bona fide established commercial or selling agencies maintained by the contractors for the purpose of securing business”: 50 App. U. S. C. A. §611.

Both Federal and State courts have construed and interpreted executive order no. 9001 differently. Some courts have held that this order directs that no person be employed on contingent fee “to solicit or secure” Government contracts because it is against public policy, tends to corrupt and amounts to a sale of persona] influence. Such agreements have been declared void, illegal and unenforceable, not because in particular cases improper influences were contemplated or used, but because of the- general tendency to overreach the public. Among the cases cited for this interpretation are LeJohn Manufacturing Company v. Webb, 222 F. 2d 48 (1955); Mitchell v. Flintkote Company, 185 F. 2d 1008 (1951); Federal Pacific Electric Company v. [194]*194McAdams, 207 Misc. 525, 139 N. Y. Supp. 2d 418 (1955), and Kribbs v. Jackson, 387 Pa. 611 (1957).

Other courts have held such contingent agreements to solicit and secure Government contracts are not illegal and void as offensive to public policy because of the mere possibility that sinister or corrupt influence may be used in their performance. There must be proof that illegal means of corrupt practices have been employed or contemplated. They further hold that this order does not expressly provide that a contractor’s agreement to pay commissions is void or voidable or unenforceable and no such provision should be read into it. Also that a violation of the executive order may create rights in the Government against the contractor, but does not render the contract void as far as agents who operate under the contract are concerned: Coyne v. Superior Incinerator Co. of Texas, 80 F. 2d 844 (1936); Hall v. Anderson, 18 Wash. 2d 625, 140 P. 2d 266; Gendon v. Jacoby, 337 Mich. 150, 59 N. W. 2d 128 (1953).

From our study of the cases, it would appear that the lower Federal courts have extended and expanded the true meaning of executive order no. 9001 to cover transactions not only between the Government and its immediate contractors, but between persons not included within its express terms. The extraordinary result is that they have given excessive authority and force to an administrative regulation or order far beyond that accorded legislation. It seems the Federal judges have tortured the language of a regulation to stamp as unlawful an act which is within normal business practice. If Congress desired to declare contingent fee contracts void and illegal, it could easily have prohibited them in no uncertain terms. Therefore, a number of State courts have rejected the decisions of the Federal courts in interpreting this executive order.

[195]*195The courts of Pennsylvania have continually upheld contracts of this type, except in cases of improper conduct by the agent: Warnock v. Philadelphia Trust Company, 69 Pa. Superior Ct. 589; Hosack v. Taylor Brothers, 142 Pa. Superior Ct. 83 (1940). There is only one Pennsylvania case mentioning executive order no. 9001, and defendant relies heavliy upon that case (Kribbs v. Jackson, 387 Pa. 611 (1957)) to sustain his preliminary objection that the contract is illegal. In this case, Justice Chidsey stated on pages 624 and 625:

“The rule is established in Pennsylvania that a contract, under the terms of which one party is to receive compensation contingent upon his obtaining Government business without disclosing to the public officers his financial interest is void. ‘. . .

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Related

Tool Co. v. Norris
69 U.S. 45 (Supreme Court, 1865)
Mitchell v. Flintkote Co.
185 F.2d 1008 (Second Circuit, 1951)
Coyne v. Superior Incinerator Co. of Texas
80 F.2d 844 (Second Circuit, 1936)
Gendron v. Jacoby
59 N.W.2d 128 (Michigan Supreme Court, 1953)
Kribbs v. JACKSON
129 A.2d 490 (Supreme Court of Pennsylvania, 1957)
Orlosky v. Haskell
155 A. 112 (Supreme Court of Pennsylvania, 1931)
Hosack v. Taylor Bros.
15 A.2d 489 (Superior Court of Pennsylvania, 1940)
Hall v. Anderson
140 P.2d 266 (Washington Supreme Court, 1943)
Federal Pacific Electric Co. v. McAdams
207 Misc. 525 (City of New York Municipal Court, 1955)
Warnock v. Philadelphia Trust Co.
69 Pa. Super. 589 (Superior Court of Pennsylvania, 1918)

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Bluebook (online)
17 Pa. D. & C.2d 191, 1958 Pa. Dist. & Cnty. Dec. LEXIS 58, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohara-v-j-w-rex-co-pactcomplmontgo-1958.