Law School Case Brief
Campbell v. Tenn. Valley Auth. - 421 F.2d 293 (5th Cir. 1969)
The measure of recovery in an action in quantum meruit, or an action on a contract implied in law, is the reasonable value of the goods or services furnished to the benefited defendant.
Plaintiff Campbell brought an action in quantum meruit against appellant to recover monies expended for the microfilming of certain technical trade journals that were a part of the technical library owned and operated by defendant Tennessee Valley Authority (TVA). An agent of the TVA ,who had no authority to contract, procured Campbell's services for the project. The district court entered a judgment upon a jury verdict for Campbell for the fair market value of microfilming work. The TVA sought appellate review of the district court's judgment.
Did the District Court err when it instructed the jury that the measure of damages in this case was the fair market value of the microfilm that benefited defendant TVA?
The United States Court of Appeals for the Fifth Circuit affirmed, holding that the measure of damages for an action brought in quantum meruit was ambiguous. The District Court was correct in using the general measure of damages and in instructing the jury that the measure of damages was "the fair market value of the microfilm that benefited TVA," instead of instructing that the measure of damages was the reasonable value of the benefit realized by TVA from the microfilm, since the actual benefit to TVA would not have been susceptible of proof. The value realized by a library in having a particular reference work available to its patrons cannot be adequately expressed in dollars and cents. The real benefit is realized, not so much by the library itself, as by those who depend upon the library in their research activities, and the benefit is not so much that the books, technical journals and other research sources are actually used, on a regular basis, but that they are conveniently available for use.
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