John T. Amend v. 485 Properties, LLC

The facts and procedural background of this case are set forth in Amend v. 485 Properties, LLC, 401 F.3d 1255 (11th Cir. 2005). In that opinion, we dismissed Amend’s contract claim and reserved ruling on his quantum meruit claim for brokerage services provided to Workplace USA, Inc. as agent for 485 Properties, LLC.

Subsequently, because we concluded that the issue of whether “procuring cause” is an element of a quantum meruit claim under Georgia law is not clear, we certified the following question to the Georgia Supreme Court: Whether procuring cause is an element of a quantum meruit claim…