North Carolina Agricultural Credit Corp. v. Boushall

Under what circumstances may an officer of a corporation recover compensation for services in the absence of an express contract ?

In Caho v. R. R., 147 N. C., p. 20, Connor, J., said: “In the absence of an express promise, made prior to the performance of the service, an officer of a corporation cannot maintain an action for compensation that he cannot sue upon a quantum meruit.” “An officer has no right to compensation for services except by express agreement preceding the services rendered.” “An agreement by the board of directors to pay an officer or director for past services, where there…