## Facts

- Lloyd Belt developed a detailed concept for a weekly radio program featuring Washington, D.C.-area high schools, with a recurring format, educational integration, and specified production logistics.
- The concept included presenting the broadcast as part of each school’s curriculum, staging performances at school assemblies, and maintaining a non-commercial style.
- Belt approached Hamilton National Bank to sponsor the program; the bank contracted with Belt for him to seek school cooperation and arrange implementation with the bank as sponsor.
- Belt met with school authorities but did not secure agreement during the life of the bank’s contract; the bank then terminated the contract.
- After termination, school officials approached the bank and proposed essentially the same program Belt had described.
- The bank sponsored a weekly radio program substantially matching Belt’s concept, arranged directly with school authorities and without Belt.
- Belt sued seeking compensation, alleging the bank appropriated his idea and was unjustly enriched.

## Issues

1. Whether a sufficiently definite and developed program concept, though an “idea,” can support restitution when disclosed in a business relationship implying an obligation to pay if used.
2. Whether termination of an express agreement bars quasi-contract recovery when the recipient later uses the disclosed concept with third parties.
3. Whether the evidence supported the jury’s finding that the bank used Belt’s concept and owed compensation in restitution.

## Decision

- The D.C. Circuit affirmed the judgment for Belt.
- The court held the concept was sufficiently concrete to fall within a class of protectable ideas when disclosed under circumstances implying an obligation to compensate upon use.
- The court rejected the argument that termination of the express contract eliminated liability for later use of the concept.
- The court upheld the jury’s verdict, finding adequate evidence that Belt originated the concept and the bank’s later program was substantially the same.

## Legal Principles

- Purely abstract or general ideas are not protected interests, but a definite, workable concept may be treated as protectable for restitution purposes when disclosed in circumstances implying payment if used.
- Quasi-contract (unjust enrichment) can require compensation when a party knowingly accepts and exploits a benefit obtained through the parties’ relationship, even if no express post-termination promise exists.
- Termination of an express contract does not foreclose restitution where the defendant retains and uses benefits derived from the plaintiff’s performance and nonpayment would be unjust.
- Appellate review defers to supported jury findings on origin of the concept, substantial similarity of use, and the fairness of imposing restitutionary liability.

## Conclusion

The court affirmed a restitutionary recovery for the bank’s post-termination use of Belt’s concretely developed radio-program concept, treating the disclosed plan as sufficiently definite to support an implied obligation to pay when later exploited without compensation.


Hamilton Nat’l Bank v. Belt, 210 F.2d 706 (D.C. Cir. 1953)