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Keywords

contractlawsuittrialmotionsummary judgmentburden of proofgood faithmotion for summary judgment
contracttrialmotionsummary judgmentmotion for summary judgment

Related Cases

Dilek v. Watson Enterprises, Inc., 885 F.Supp.2d 632

Facts

Emel Dilek was employed by Watson Enterprises, Inc. and had a romantic relationship with the company's COO, Ronald Pecunies. In January 2009, they signed an employment agreement that guaranteed Dilek a four-year term of employment. After Pecunies passed away in May 2010, the company terminated Dilek's employment in August 2010, leading her to file a lawsuit alleging breaches of contract and good faith.

Dilek and Pecunies first met on January 28, 2004, and they began a romantic relationship shortly thereafter. On or about January 1, 2009, Pecunies (purportedly on behalf of WEI) and Dilek signed an employment agreement, which provided that Dilek would continue for a four-year term of employment as WEI's Business Development Center and Marketing Manager.

Issue

Did Ronald Pecunies have the authority to bind Watson Enterprises, Inc. to the employment agreement with Emel Dilek, and were the employer's counterclaims valid?

The parties' dispute centers on whether Pecunies had authority sufficient to bind WEI to the Employment Agreement and, as a result, whether the signing of the Employment Agreement was the formation of a valid contract that was binding on WEI.

Rule

Under Connecticut law, an agent's authority may be actual or apparent, and the principal is bound by the acts of the agent within the scope of that authority. The burden of proof regarding the agent's authority lies with the party challenging it.

Under Connecticut law, an agent's authority may be actual or apparent.

Analysis

The court analyzed whether Pecunies had actual or apparent authority to enter into the employment agreement with Dilek. It found that there were genuine disputes of material fact regarding Pecunies's authority, as he had previously informed Dilek of her promotions and raises, and Watson had taken a hands-off approach to her employment due to their relationship. The court concluded that the employment agreement was not unusual in a legal sense, thus shifting the burden to the employer to prove Pecunies lacked authority.

The evidence behind these assertions is sufficient to create genuine issues of material fact as to whether authority to offer the Employment Agreement was 'authority which the principal [WEI] intended [its] agent [Pecunies] to possess.'

Conclusion

The court denied Watson Enterprises' motion for summary judgment and granted Dilek's motion in part, indicating that the case would proceed to trial to resolve the factual disputes regarding Pecunies's authority.

The court denied Watson Enterprises' motion for summary judgment and granted Dilek's motion in part, indicating that the case would proceed to trial to resolve the factual disputes regarding Pecunies's authority.

Who won?

Emel Dilek prevailed in part as the court found that there were genuine issues of material fact regarding the authority of the COO to bind the company to the employment agreement.

Emel Dilek prevailed in part as the court found that there were genuine issues of material fact regarding the authority of the COO to bind the company to the employment agreement.

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