A Guide to Quantum Meruit in Minnesota | Attorney Aaron Hall

A Guide to Quantum Meruit in Minnesota

What is Quantum Meruit?

Translated, quantum meruit means “as much as he merited” or “as much as he/she deserved.” In law, quantum meruit is a doctrine that allows someone to recover the value of services provided to another when there was no actual contract but the one receiving services understood payment would be required.

How is Quantum Meruit Used in Minnesota?

“Recovery in quantum meruit may be obtained where a benefit is conferred and knowingly accepted under such circumstances that would make it unjust to permit its retention without payment.” In re Stevenson Assocs., Inc., 777 F.2d 415, 421 (8th Cir. 1985).

What Amount is Owed for Quantum Meruit?

The amount you can recover under quantum meruit is the reasonable value of the benefit derived, which is based on either market prices or negotiations of the parties.

A party may recover under quantum meruit where he or she has conferred a benefit to another and has not received reasonable compensation for this act. See, e.g., Frankson v. Design Space Int’l, 394 N.W.2d 140, 145 (Minn. 1986). Under quantum meruit, the measure of recovery for a partially completed project is “the reasonable value of the fraction of the project that was completed.” E.C.I. Corp. v. G.G.C. Co., 306 Minn. 433, 437, 237 N.W.2d 627, 630 (Minn. 1976). Determination of the “reasonable value” can be based on the contract price, even though recovery is sought in equity. Confer Bros. v. Currier, 164 Minn. 207, 210, 204 N.W. 929, 931 (Minn. 1925).

Busch v. Model Corp., 708 N.W.2d 546, 552 (Minn. Ct. App. 2006)

How is Quantum Meruit Different from a Contract?

Quantum meruit is not available if a contract exists.

Recovery in quantum meruit may be obtained where a benefit is conferred and knowingly accepted under such circumstances that would make it unjust to permit its retention without payment. Ylijarvi v. Brockphaler, 213 Minn. 385, 393 (1942) ; see generally 17 C.J.S. § 6, at 572–73 (1963 & Supp.1985). However, there can be no recovery in quantum meruit where a valid express contract between the parties exists. Breza v. Thaldorf, 276 Minn. 180, 183, 149 N.W.2d 276, 279 (1967); Schimmelpfennig v. Gaedke, 223 Minn. 542, 548, 27 N.W.2d 416, 420–21 (1947). Parties to an express contract are entitled to have their rights and duties adjudicated exclusively by its terms. See Starr v. Starr, 312 Minn. 561, 562–63, 251 N.W.2d 341, 342 (1977); Carl Bolander & Sons, Inc. v. United Stockyards Corp., 298 Minn. 428, 433, 215 N.W.2d 473, 476 (1974).

See In re Stevenson Assocs., Inc., 777 F.2d 415, 421 (8th Cir. 1985)

Minnesota law is clear that “[w]here an express contract exists, there can be no implied [in law] contract with respect to the same subject matter.” Reese Design v. I–94 Highway 61 Eastview Center Partnership, 428 N.W.2d 441, 446 (Minn. App. 1988); accord Sharp v. Laubersheimer, 347 N.W.2d 268, 271 (Minn. 1984). On the other hand, if an existing contract does not address the benefit for which recovery is sought, quantum meruit is available regarding those items about which the contract is silent. Holman v. CPT Corp., 457 N.W.2d 740, 745 (Minn. App. 1990); Frankson v. Design Space Int’l, 394 N.W.2d 140, 145 (Minn. 1986); Sagl v. Hirt, 236 Minn. 281 (1952).

See Ventura v. Titan Sports, Inc., 65 F.3d 725, 730 (8th Cir. 1995).

What Claims are Related to Quantum Meruit?

Quantum meruit is one of many equitable remedies available at common law. Similar remedies include quantum valebant, unjust enrichment, promissory estoppel, contract implied in fact, and contract implied in law (quasi contract).

This article was written by attorney Aaron Hall.