Quantum valebant is exactly like quantum meruit, but with one important distinction: quantum meruit applies to the value services, while quantum valebant applies to the value of goods. Translated, quantum valebant means “as much as they were worth.”
Minnesota courts have recognized quantum valebant as a remedy allowing the provider of goods to recover the value of the benefit provided:
Under an implied contract for quantum valebant, the theory of recovery is similar to that in unjust enrichment; the party seeking relief is allowed to recover for the value of the benefit received. See, e.g., Tracy Cement Tile Co. v. City of Tracy, 143 Minn. 415, 418 (Minn. 1919) (“When a contract which a municipality had the power to make has been performed, with the acquiescence of the municipality, and the municipality has received the benefit, it has been held that recovery may be had on quantum valebant.”).
Interboro Packaging Corp. v. City of Minneapolis, No. A09-0189, 2009 WL 2928755, at *9 (Minn. Ct. App. Sept. 15, 2009).
Some courts have considered quantum valebant as part of the doctrine of implied in fact contracts. See Urban Data Systems, Inc. v. United States, 699 F.2d 1147, 1154–55 (1983).
If you sell goods to someone, even if there is no contract, they must pay you for the value of those goods.
This article was written by attorney Aaron Hall.