Is a horse owner always obligated to pay the bills for necessary goods and services arranged by a trainer but provided by a third party?
Probably, at least according to the Appellate Division of the Superior Court of New Jersey.
The case involved a Standardbred owner, a trainer, a veterinarian, and a horse named River Runs Red. The issue was whether the owner was responsible obligated to pay $1,866 for veterinary treatment authorized by the trainer. The veterinarian testified that he had talked with the owner, who told him to "do everything you have to do to take care of my horse." The veterinarian also testified that the trainer had authorized and approved the specific veterinary work done on River Runs Red.
The horse owner did not dispute that the veterinary services that were billed had been performed, or that the work was necessary. The vet work included vaccinations for rabies, influenza, and rhinopneumonitis, which were required by the race tracks where River Runs Red competed. Nor was it disputed that the trainer had requested the veterinary work for River Runs Red.
The trial judge found the horse owner to be the more credible witness. Based on the owner’s testimony that there had been no conversation between the owner and the veterinarian, the judge determined that there had been no express contract between the two that would obligate the owner to pay the vet bill for River Runs Red. The judge would not allow the veterinarian’s attorney to pursue a claim based on the fact that the trainer was an agent of the owner. This was an odd ruling, considering that an agency relationship between a horse owner and a trainer usually goes without saying in the horse business.
Agency is a legal relationship in which one individual (called the "principal") gives another individual (called the "agent") authority to act on the principal’s behalf. When this happens, the acts of the agent obligate the principal to complete the transaction. This relationship is what allows a bloodstock agent to buy a horse on behalf of someone else, who must ultimately pay for the animal. With a few exceptions, the agent incurs no financial liability in the transaction.
The veterinarian appealed the decision. The appellate court also skirted the agency issue but reversed the trial court and ruled in the veterinarian’s favor anyway. Assuming that there had been no conversation between the horse owner and the veterinarian, and assuming that the trainer had no actual authority to contract for the services on behalf of the owner, the court found that the veterinarian still could recover under a legal theory called "quantum meruit." This simply means that a person who does something for someone else with an expectation of getting paid, should get paid. Even without a contract for the services, the court found that the veterinarian could pursue a claim for the reasonable value of the services he provided.
Any value as legal precedent the court ruling might have stops at the New Jersey border. Courts in one state are not obligated to follow rulings from other states. The New Jersey ruling does bring up a sound legal argument, however, that can be raised in other jurisdictions as an added protection for veterinarians and other providers of goods and services.
The case is Danvers v. Bilach, No. A-4608-08T2 (N.J. Superior Ct, App. Div., Dec. 29, 2009).