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Keywords

contractattorneyappealtrialwillimplied contract
contractattorneyappealtrialwillimplied contract

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Felton v. Finley, 69 Idaho 381, 209 P.2d 899

Facts

Seigle Coleman died testate, leaving a will that was contested by two of his nephews, Seigle and William Finley, who hired attorney J. H. Felton on a contingent fee basis. The other heirs, including Orval Finley and three sisters, refused to sign contracts with Felton or participate in the contest. Despite their non-participation, after the contest was successful, the other heirs sought to claim their shares of the estate, leading Felton to file a suit to establish an implied contract and enforce a lien for his fees.

Seigle Coleman died testate, leaving a will that was contested by two of his nephews, Seigle and William Finley, who hired attorney J. H. Felton on a contingent fee basis. The other heirs, including Orval Finley and three sisters, refused to sign contracts with Felton or participate in the contest. Despite their non-participation, after the contest was successful, the other heirs sought to claim their shares of the estate, leading Felton to file a suit to establish an implied contract and enforce a lien for his fees.

Issue

Did an implied contract of employment exist between J. H. Felton and the other heirs of Seigle Coleman, despite their refusal to sign contracts or participate in the will contest?

Did an implied contract of employment exist between J. H. Felton and the other heirs of Seigle Coleman, despite their refusal to sign contracts or participate in the will contest?

Rule

An implied contract to pay for services may arise when one party accepts the benefits of services rendered by another, unless it is established that such services were intended to be gratuitous.

An implied contract to pay for services may arise when one party accepts the benefits of services rendered by another, unless it is established that such services were intended to be gratuitous.

Analysis

The court analyzed the actions of the heirs, noting that while they did not actively participate in the contest, they accepted the benefits of Felton's services after the successful outcome. However, the court emphasized that the acceptance of benefits does not automatically create an implied contract to pay, especially when the parties had previously refused to engage Felton's services.

The court analyzed the actions of the heirs, noting that while they did not actively participate in the contest, they accepted the benefits of Felton's services after the successful outcome. However, the court emphasized that the acceptance of benefits does not automatically create an implied contract to pay, especially when the parties had previously refused to engage Felton's services.

Conclusion

The appellate court reversed the trial court's decree, concluding that there was no implied contract of employment between Felton and the other heirs, as they had not authorized his employment and had explicitly refused to engage him.

The appellate court reversed the trial court's decree, concluding that there was no implied contract of employment between Felton and the other heirs, as they had not authorized his employment and had explicitly refused to engage him.

Who won?

Orval Finley and the other heirs prevailed in the appeal because the court found that they had not entered into an implied contract with Felton for his services.

Orval Finley and the other heirs prevailed in the appeal because the court found that they had not entered into an implied contract with Felton for his services.

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