The United Arab Emirates (UAE), a country in the Middle East, held a competition for the architectural design of a new embassy it intended to build in Washington DC. Elena Sturdza, an architect licensed in Maryland and Texas, entered the competition and submitted a design. After reviewing all of the submitted designs, UAE notified Sturdza that she had won the competition. UAE and Sturdza entered into contract negotiations, and over the next two years, they exchanged multiple contract proposals. During that time, at UAE’s request, Sturdza modified her design. She agreed to defer billing UAE for her work until the execution of their contract. At last, UAE sent Sturdza a final agreement. Sturdza informed UAE that she assented to the contract. Without explanation, however, UAE stopped communicating with Sturdza. UAE hired another architect to design the embassy. Sturdza filed suit against UAE to recover damages for breach of contract or, alternatively, under equity, to prevent unjust enrichment to UAE. UAE defended, alleging that because Sturdza did not have an architectural license issued by Washington DC, she could not recover damages. Was there an illegal contract? Was it ethical for UAE not to pay Sturdza? Sturdza v. United Arab Emirates, 11 A. 3d 251, 2011 D. C. App. Lexis 2 (District of Columbia Court of Appeals, 2011)

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