Quantum Meruit as a Cause of Action in New York
Quantum meruit, Latin for “as much as he has earned,” is an equitable cause of action used in New York when there is no enforceable contract, but one party seeks compensation for services rendered. This legal theory allows recovery for the value of work performed when a person has benefitted from services and it would be unjust for them not to pay. In New York, courts have clearly defined the elements necessary to establish a claim for quantum meruit. Below are the four key elements to prove a quantum meruit claim.
1. Performance of Services in Good Faith
To succeed on a quantum meruit claim, the plaintiff must first demonstrate that they performed services in good faith. This means the work must have been provided honestly and without fraud, coercion, or deceit. Courts look at whether the service provider acted with integrity and whether the services offered were lawful and proper under the circumstances.
2. Acceptance of Services by the Recipient
The next element requires proof that the defendant accepted the services. Acceptance can be express—such as when the recipient agrees to let the work be done—or implied, when the services are received without objection and used for the benefit of the defendant. Without evidence of acceptance, there is no basis to imply a promise to pay.
3. Expectation of Compensation
The plaintiff must also show that the services were rendered with the expectation of payment. This distinguishes quantum meruit from gifts or volunteer efforts. Courts assess whether it was reasonable for the provider to expect compensation and whether that expectation was apparent to the recipient at the time the services were rendered.
4. Reasonable Value of the Services
Finally, a plaintiff must establish the reasonable value of the services provided. This is typically proven through expert testimony, industry standards, or documentation of the time and labor involved. The court will not award compensation beyond the fair market value of the work.
Conclusion
Quantum meruit is often used when a formal contract does not exist, but fairness demands payment for services rendered. It ensures that individuals who provide services in good faith are not left uncompensated when another party has clearly benefitted. In New York, meeting all four elements is essential to prevail on this claim, and successful plaintiffs are those who can clearly show their intent, performance, and the value they delivered.
Find the Law
“The elements of a claim for quantum meruit are: [1] the performance of services in good faith; [2] the acceptance of services by the person to whom they are rendered; [3] an expectation of compensation and [4] the reasonable value of the services. Miranco Contracting Corp. v. Perel. 57 AD3d 956 (2nd Dept. 2008).” John Anthony Rubino Co., CPA, P.C. v. Schwartz, 2010 N.Y. Slip Op. 51585, 6 (N.Y. Sup. Ct. 2010).