Braude v. Robb, 279 A.3d 1153

Braude (owner) and Robb (longtime trainer) disputed an oral agreement to have Robb claim a horse, Hydra, in a January 4, 2020 Laurel Park claiming race.
Braude completed an Authorized Agent form, wired $25,000 (plus $1,500 tax), and testified Robb repeatedly promised to drop a claim slip for Hydra.
Video and testimony show interactions in the paddock; Robb later dropped a claim slip signed for Eugene Gould, Jr.; Hydra’s Equibase record listed Gould as owner and Robb as trainer.
Braude sued in circuit court for breach of contract (including promissory estoppel/detrimental reliance), breach of fiduciary duty, and fraud; bench trial resulted in judgment for Robb on the contract and fiduciary claims (court found no consideration and no exclusive agency) and the court did not separately analyze fraud.
On appeal the Court of Special Appeals held the trial court erred by failing to consider detrimental reliance and by misunderstanding fiduciary duties when an agent purportedly acts for two principals with respect to the same horse; the court remanded for a new trial, including on fraud.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence/enforceability of an oral contract to claim Hydra	Braude: Robb promised to claim Hydra; Braude relied (wired funds, signed agent form); promissory estoppel/detrimental reliance supplies consideration	Robb: No contract—Braude never timely notified he had funds; Robb’s promise was gratuitous/conditional	Trial court’s failure to resolve credibility/detrimental reliance was error; remand for findings and retrial on contract/detrimental reliance
Breach of fiduciary duty based on agency to claim horses	Braude: Authorized Agent form made Robb his agent; Robb owed loyalty and disclosure and breached by claiming for another client	Robb: Non-exclusive trainer; routinely claims for multiple clients and had told Braude he wouldn’t/needed confirmation	Court: An agent owes fiduciary duties and may not act for competing principals as to the same horse; trial court erred—remand for fact/findings on breach
Fraud (fraudulent misrepresentation)	Braude: Robb knowingly or recklessly misrepresented that he would claim Hydra, inducing reliance and damages	Robb: Representations were vague/conditional; Braude (experienced) should have inquired or submitted his own claim	Although trial court disposed of the case without separately analyzing fraud, appellate court found error and remanded for retrial on fraud

Ins. Co. of N. Am. v. Miller, 362 Md. 361 (2001) (defines agency as fiduciary relation arising from principal’s manifestation of consent)
Green v. H & R Block, Inc., 355 Md. 488 (1999) (agent’s duty of loyalty and obligation to disclose conflicts and material information)
Pavel Enters., Inc. v. A.S. Johnson Co., 342 Md. 143 (1996) (adopts Restatement test for detrimental reliance/promissory estoppel)
Swinson v. Lords Landing Vill. Condo., 360 Md. 462 (2000) (elements required to prove fraudulent misrepresentation)
Cochran v. Norkunas, 398 Md. 1 (2007) (objective interpretation of contracts; mutual assent and acceptance principles)
C–E–I–R, Inc. v. Computer Dynamics Corp., 229 Md. 357 (1962) (agent’s duties include loyalty and avoidance of conflicts)