This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
Where the authority given to a broker to effect a sale of land does not require the contract of sale to be in writing, the agreement to pay him a commission is not within the statute of frauds, and is valid, though not in writing. Low Moor Iron Co. of Va. v. Jackson, 84 S. E. 100, 117 Va. 76.
 
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