“The law of the District of Columbia has imposed a licensure requirement on the practice of architecture in this jurisdiction in order to safeguard life, health, and property, and to promote the public welfare.” —Glickman, Associate Judge 

Facts: 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. At UAE’s request, Sturdza modified her design. UAE sent Sturdza a final agreement to which Sturdza assented. However, UAE subsequently stopped communicating with Sturdza and hired another architect to design their embassy. Sturdza filed suit against UAE to recover damages for breach of contract. UAE defended, alleging that because Sturdza did not have an architectural license issued by Washington, DC, she could not recover damages. The case was heard by the District of Columbia Court of Appeals. 

Issue: Does Sturdza’s lack of a District of Columbia’s architect license bar her from recovering damages from UAE? 

Language of the Court: District of Columbia law bars an architect from recovering on a contract to perform architectural services in the District if the architect lacked a District of Columbia architect’s license when he or she negotiated or entered into the contract or when he or she performed the architectural services. The law of the District of Columbia has imposed a licensure requirement on the practice of architecture in this jurisdiction in order to safeguard life, health, and property, and to promote the public welfare. 

Decision: The District of Columbia Court of Appeals held that Sturdza could not recover damages from UAE because she did not possess the required architectural license to practice architecture in the district. 

Ethics Questions: Was it ethical for Sturdza to do the work without being licensed in the District of Columbia? Was it ethical for UAE not to pay Sturdza?