CASTILLO v. BARRERA
In action for breach of oral contract and quantum meruit based on services allegedly rendered to defendant, a professional boxer, plaintiff's allegations that he rendered those services in the capacity of a manager constituted a binding judicial admission fatal to the claims because plaintiff was unlicensed, and California law requires that boxing managers be licensed and that contracts be in writing on a form approved by the State Athletic Commission. Plaintiff's allegations that he agreed to assume responsibility as defendant's manager in accord with the established custom in the professional boxing industry in exchange for a percentage of defendant's earnings; that he played a direct role "in all matters" pertaining to defendant's boxing career, "including, without limitation, managing his business and personal affairs;" that he negotiated defendant's promotional contract; that he made diligent efforts to settle three lawsuits involving defendant to extricate defendant from "career turmoil;" that he played a direct and instrumental role in settlement of three lawsuits, "thereby allowing [defendant] to continue with his professional boxing career;" and that he worked with an attorney to extricate defendant from tax problems and helped him obtain medical clearances "which could have otherwise hampered or damaged his career" established as a matter of law that plaintiff was acting in the capacity of a manager. Plaintiff's allegations that he performed 400 or more hours of work on defendant's behalf did not entitle him to recovery in quantum meruit where it was established that plaintiff acted in the capacity of a boxing manager despite the lack of a license and a written contract. To allow recovery in that circumstance would be contrary to the regulatory purpose of the Boxing Act. Where plaintiff entered into purported manager's contract with defendant in California and sued to enforce it in a California court, state's "unusually strong" public policy interest in regulating boxing supported application of California law to activities in connection with a bout that took place in another state.
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