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.
In an action by a broker to recover commissions for a sale of land, it appeared that some months after the authority to sell had been revoked for failure of the broker to procure a purchaser, the owners sold the land to one with whom the broker had attempted to engotiate a sale. Held, error to submit the cause to the jury to determine whether the plaintiff was the efficient cause in procuring the sale, and, on defendant's request, to charge that defendant had the right to terminate his employment at any time, if he did not within a reasonable time produce a purchaser, to reply: "I have already charged that, but that does not prevent him from being entitled to the fruits of the seed he had already sown." Donovan v. Weed, 182 N. Y. 43, 74 N. E. 563.
 
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