Sturdza v. United Arab Emirates

Summary

The District of Columbia Court of Appeals answered a certified question concerning whether an architect unlicensed in the District could recover under contract or quantum meruit for architectural services performed there. The court held that District law generally bars recovery when the architect lacked a District license while negotiating or entering into the contract or performing the services, even if licensed elsewhere. The court also held that neither international design competitions nor services for foreign embassies created an exception, while recognizing a former statutory exception requiring licensure before performance.

Holdings

1. District of Columbia law bars an architect from recovering on a contract to perform architectural services in the District or in quantum meruit for architectural services rendered there if the architect lacked a District of Columbia architect's license when negotiating the contract, entering into it, or performing the services, even if licensed in another jurisdiction.
2. The former D.C. Code § 2-262(6) exception allowed an architect licensed elsewhere to negotiate and enter into a District architectural-services contract without being subject to the recovery bar only if the architect obtained a District license before performing any services. Because Sturdza substantially performed services before obtaining a District license, she could not invoke the exception.
3. There is no exception to the District's architectural licensing requirement for international design competitions, submission of bids, services for foreign embassies, public buildings, or monuments. Federal laws concerning foreign missions and the International Center did not preempt or displace the District licensing requirement.

Questions Presented

1. Whether District of Columbia law bars an architect from recovering on a contract to perform architectural services in the District when the architect lacked a District of Columbia license while negotiating or entering into the contract.
2. Whether District of Columbia law bars an architect from recovering in quantum meruit for architectural services rendered in the District while unlicensed there.
3. Whether the former statutory exception for architects licensed in another jurisdiction permitted Sturdza to recover despite her lack of a District of Columbia license.
4. Whether international design competitions, bids for foreign embassies, or federal laws governing foreign missions exempt architectural services from the District's licensing requirement.

Disposition

other