Where a property owner, with knowledge of the custom of real estate agents to charge both parties commissions on exchange of property, allows the broker to render the services and remains silent, the broker is entitled to recover a commission from him. Barney v. Sturgeon, 86 S. E. 660, 17 Ga. App. 292.

A valid, binding ratification, when made, can not be revoked, but the principal must abide by it, whether it be to his detriment or to his advantage. Watterson v. Rogers, 21 Kan. 529. In the absence of express ratification by the principal, there must be an appropriation by him of the services of the broker under such circumstances as would render the withholding of remuneration therefor inequitable. Atwater v. Lockwood, 39 Conn. 45; Albany Land Co. v. Rickel, 162 Ind. 222, 70 N. E. 158, Ettinger v. Weatherhead, 29 Ohio Cir. Ct. R. 137.

W, the president of the defendant company, agreed to pay the plaintiff a commission for procuring a purchaser of land which they thought belonged to W, but which belonged to the company, plaintiff procured a purchaser and W sold him the land - the company knew nothing of the contract with plaintiff, but ratified the sale and made a deed to the purchaser. Held, that plaintiff could not recover commissions from the company. Copeland v. Stoneham Tannery Co., 142 Pa. St. 446, 21 Atl. 825.

A contract of sale of realty was made by one having no title nor authority to execute such an instrument; the attorney for the purchaser was informed by the equitable owner that such person was authorized to sell. Held, that such statement was a ratification of the agent's authority which estopped the equitable owner from denying it. Gregg v. Corey, 4 Cal. App. 354. 88 P. 282.

Where an agent is authorized to procure a purchaser for real estate at a fixed sum and for a stipulated compensation, he can recover the compensation when he procures a purchaser to whom the owner sells, although he accepts a less sum than that at which he authorized the agent to sell. Ice v. Maxwell, 61 W. Va. 9, 55 S. E. 899; Weeks v. Smith (N. J. Sup. '10), 75 A. 773.

Where the defendant put real estate in the hands of the plaintiff to sell, directing him not to sell it, but, nevertheless, forgetting the injunction placed upon him he did advertise the property, and a person reading the same went directly to the defendant who sold him the property, this was a ratification of plaintiff's departure from instructions, and the defendant was liable to the plaintiff for commissions. Maloon v. Barrett, 192 Mass. 552, 78 N. E. 560.

Where plaintiff, having obtained from the defendant a statement as to the price and terms at which to sell certain real estate, found a person able and willing to purchase on the terms stated, and notified the defendant, enclosing a deed for execution, which defendant executed and sent to one R, with a letter constituting R, his agent, to deliver the deed and complete the sale, if the terms were the best obtainable, defendant, through the said agent R, refused to accept such terms and refused to deliver such deed. Held, that these facts amounted neither to an acceptance of the plaintiff's proposal, nor to a ratification of the unauthorized acts of plaintiff in negotiating with a third person for the purchase of the property. Harris v. Reynolds (North Dak. '07), Supreme Court, 114 N. W. 369.

If a broker undertakes to modify his authority the principal may repudiate and decline to be bound thereby, or he may ratify his act and be bound by the change. Phinizy v. Bush, 129 Ga. 479, 59 S. E. 259. In a suit for commissions for finding a purchaser for land listed with brokers, and by them relisted with plaintiff's firm, it was essential to authorize a recovery that the land was so relisted by authority from defendant, either express or implied, unless after the land was listed with the first brokers, they so relisted it, and, defendant being aware of it, ratified the act. Sterling v. DeLaune (Tex. Civ. App. '07), 105 S. W. 1169.

Under the Missouri statute providing that no contract for the sale of real estate, made by an agent, shall be binding unless the agent be authorized in writing to make the contract, the ratification of the contract by the principal for the sale of land by the agent must be in writing, where no element of equitable estoppel exists. Johnson v. Fecht, 185 Mo. 335, 83 S. W. 1077.

Under Burns's Stat. 1908, sec. 7463, requiring a contract for a commission for the sale of land to be in writing, signed by the owner or his representative, held, as an owner could not sign his name by the broker, his subsequent statement to the broker that he would pay the commission stated in the contract signed by the broker could not amount to a ratification. Lowe v. Mohler, 105 N. E. 934, 56 Ind. App. 593.

Where a third party conducted negotiations, procured a loan, and drew the note and mortgage, on which suit was based, for defendant, though not authorized directly to do so for them, and they accepted the loan and executed the note and mortgage, they thereby ratified the acts of such third party and were bound thereby as effectually as though they had expressly authorized him to act as their agent. Marks v. Taylor, 23 Utah, 470, 63 P. 897, 65 P. 203.

Where the contract of a sub-agent is ratified by the owner, in case of a sale the sub-agent may sue the owner for the commission, and is not limited to his action against the broker employing him. Warren Com. & Inv. Co. v. Hull B. E. Co., 120 Mo. App. 432, 96 S. W. 1038; Mechem on Agency, Secs. 197, 227.

Under L. O. L. sec. 808, requiring brokers' authority to sell lands to be in writing, with the owner's consent to sales to a purchaser procured by a sub-agent of his broker, with knowledge that the purchaser had been so procured, was not such a ratification of the sub-agent's oral employment as would hold the owner for a commission. Sorensen v. Smith, 129 P. 757, 65 Or. 78, 51 L. R. A. (N. S.) 612, Ann. Cases 1915 A, 1127; judg. aff'd on re. 131 P. 1022, 65 Or. 78.

Where the owner at first refuses an offer as too low, and discharges the broker, and thereafter, through another broker, accepts, he is liable to the first broker for commissions, the sale having been made to his customer at the price originally offered. Gotischalk v. Jennings, 1 La. Ann. 5; Cadigan v. Crabtree, 179 Mass. 474, 61 N. E. 37, 55 L. R. A. 77; Buehler v. Weiffenbach, 46 N. Y. S. 861, 21 Misc. 30; Peckham v. Ashhurst, 18 R. I. 376, 28 A. 337.

Where a broker sent a customer to his principal, and the customer told him that the broker had shown him the land, this was held sufficient to bind and obligate the principal to pay the broker for the services he rendered in procuring the purchaser. Reishus-Reiner Land Co. v. Benner, 91 Minn. 401, 98 N. W. 186.

A co-agent, under a power to sell, is not bound by an unauthorized option, not given or ratified by himself, and if he purchases the land for himself, can not be held as a trustee for the claimant under the option. Tibbs v. Zirkle, 55 W. Va. 49, 46 S. E. 701, 104 Am. St. R. 977. An owner who has sanctioned sales by accepting the proceeds can not contend that the power of attorney did not authorize the sales. Vaughn v. Sheridan, 50 Mich. 155. A principal appropriating the benefits of an unauthorized act of a broker becomes liable by the ratification to compensate him for his services. Merrill v. Latham, 8 Colo. App. 263, 45 P. 524; Downing v. Buck, 135 Mich. 636, 98 N. W. 388; Dayton v. Am. Steel Barge Co., 73 N. Y. S. 316, 36 Misc. 223; Barbour v. Cantrell, 69 S. 67, 193 Ala. 154; Duncan v. Turner, 154 S. W. 816, 171 Mo. App. 661; Wilson v. Burch, 162 S. W. 1018, - Tex. Civ. App. -; Henderson & Grant v. Gilbert, 171 S. W. 304; Fishback v. Vining, 125 P. 559, 22 Colo. App. 419; Record v. Littlefield, 106 N. E. 142, 218 Mass. 483; Stevens v. Odlin, 84 A. 899, 100 Me. 417; Crumpacker v. Jeffrey, 115 N. E. 62, - Ind. App. - .

A real estate agent inquired of an owner whether he would sell real estate for $6,500 cash, clear of special taxes. The owner replied that he would sell for that sum, net. The agent contracted with a purchaser for a sale at $7,000, payable on delivery of a warranty deed and abstract, all assessments to be paid, and notified the owner of the sale and requested an abstract. The owner sent an abstract, and stated that it was his understanding that the price was $6,500 net, and that he would pay no back taxes or any other expenses. Held, that the contract was not enforceable against the owner, since he neither authorized the agent to make it. nor ratified it. Hutchins v. Wertheimer, 51 Wash. 539, 99 P. 577. See references under Sec. 307.

Owner of lots held to have accepted and approved real estate agent's plan to sell the lots subject to building restrictions by executing deeds containing the restrictions. Wiegman V. Kusel, 110 K. E. 884, 270 I11. 520.

General power of attorney from a widow is sufficient to authorize the holder to agree on her behalf to pay a commission for selling her land, authorized, after a sale, the reduction of the agreement to writing correcting the defect of the parol agreement, under Civil Code, see. 2307, providing that an agency may be created by ratification. Stieglitz v. Settle, 165 P. 436, - Cal. Sup. - .

Where real estate brokers, who undertook to trade lands to defendant's satisfaction, and in such manner that defendant would get a small tract of 80 or 120 acres, actually made a trade for town property which defendant ratified and carried out, defendant is conclusively presumed to have been satisfied, and is liable for commission. Peterson v. Wilds, 173 N. W. 126, - Iowa Sup. - .