Dinan v. Alpha Networks, Inc., No. 13-1976 (1st Cir. 2014)
Annotate this CaseFrom 2005 to 2010, Plaintiff, a Maine resident, worked as a salesman for Alpha Networks, which was based in California, pursuant to a written employment agreement. Plaintiff left Alpha having received no commissions on his sales in 2009 or 2010. Plaintiff then filed suit. A jury concluded that Alpha had not promised to pay Plaintiff commissions after 2008 but concluded that Plaintiff was entitled to damages in the amount of $70,331 under quasi-contract. After trial, the parties disputed whether California or Maine law governed whether and to what extent the jury’s damages award should be augmented with additional remedies. Under California law, Plaintiff would be entitled to an additional award of $7,799, but under Maine law, Plaintiff would be entitled to an additional $140,663, as well as attorneys’ fees and costs. The district court concluded that California law applied. The First Circuit vacated the award and remanded, holding that Maine substantive law governed enforcement of the quasi-contractual relationship found to exist between the parties in 2009 and 2010.
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