## Facts

- Ted Raden claimed he was employed to represent and manage Rosetta Jacobs (known professionally as Piper Laurie), a minor actress, with the involvement of her mother and guardian, Charlotte Jacobs.
- In January 1948, the parties signed a writing employing Raden as a nonexclusive manager to secure engagements for the actress (subject to the consent of the actress and her guardian) in exchange for a 10% commission on monies received from engagements obtained directly or indirectly by Raden; the writing stated no duration.
- On July 30, 1948, the parties executed a second written agreement that, as described in the affidavits and pleadings, reframed Raden’s role toward advice and counsel in business and financial matters while retaining the same 10% commission structure.
- Charlotte Jacobs asserted Raden presented the July agreement as merely a “better form,” not a substantive change in the arrangement.
- It was undisputed that Raden was not licensed as an employment agent or artists’ manager and that the agreement was not approved by the California Labor Commissioner.
- Raden alleged the actress earned substantial sums from professional services and sought $3,100 as unpaid commissions under the July agreement.
- The actress disaffirmed and terminated the July 30, 1948 agreement by written notice dated October 12, 1949.

## Issues

1. Whether Raden’s activities and contracts placed him within the Labor Code provisions regulating private employment agencies and artist managers, requiring licensure and Labor Commissioner approval.
2. Whether Raden could enforce a commission agreement despite being unlicensed and lacking statutory approval for the contract.
3. Whether the minor’s disaffirmance of the contract independently barred enforcement.
4. Whether summary judgment was proper given the pleadings and affidavits.

## Decision

- The Court of Appeal affirmed summary judgment for Charlotte Jacobs.
- The court treated the agreements as falling within the statutory regulation of persons who secure or attempt to secure employment for artists.
- Because Raden was unlicensed and the agreement was not approved by the Labor Commissioner, the court held the commission claim was barred as a matter of law.
- The minor’s disaffirmance further defeated enforcement of the July 30, 1948 agreement.
- No triable issue of material fact existed that would permit Raden to recover commissions; summary judgment was appropriate.

## Legal Principles

- A person who secures or attempts to secure employment for an artist under a commission arrangement is subject to Labor Code licensing and contract-approval requirements governing private employment agencies and artist managers.
- A contract made in violation of a public-protection regulatory statute (including required licensure and administrative approval) is unenforceable by the unlicensed party seeking compensation under it.
- Labels in a contract do not control; an arrangement framed as “advice and counsel” may still be treated as regulated talent-placement activity when compensation is tied to the artist’s employment earnings and the relationship in substance involves obtaining engagements.
- A minor may disaffirm a contract, and disaffirmance provides an additional bar to enforcement against the minor and related parties.

## Conclusion

The court held that an unlicensed representative could not recover commissions under an entertainment-management agreement subject to Labor Code licensing and Labor Commissioner approval requirements, and the minor’s disaffirmance further prevented enforcement; summary judgment for the guardian was affirmed.


Raden v. Laurie, 120 Cal. App. 2d 778, 262 P.2d 61 (Cal. Ct. App. 1953)