This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
A judgment dismissing an action on an express promise to pay an agreed commission for selling land, entered on a finding that plaintiff did not act as agent for defendant in the sale, and that there was no contract for a commission, is a bar to a subsequent action for the same commission based on an express promise to pay the reasonable value of the services after they were performed. Krug v. Hendricks (Wash. Sup. '09), 102 P. 1049.
 
Continue to: