The underlying idea behind quantum meruit is the law's distaste for unjust enrichment. If one has received a benefit which one may not justly retain, one should restore the aggrieved party to his former position by return of the thing or its equivalent in money.
A boyfriend and girlfriend held themselves out as a married couple, the girlfriend used the boyfriend's name, they lived together and worked together at boyfriend's company. The value of the company increased during the 20 years they worked together, in part due to the girlfriend's efforts. She filed suit upon the breakup and sued, alleging, among other things, breach of contract, breach of fiduciary duty, and quantum meruit. The trial court's instructions allowed the jury to award her $ 84 million as her contribution for services into the company over the years, which the boyfriend contested. The case was appealed to the Court of Appeal of California.
Did the court give proper instructions to the jury?
The court reversed and remanded because the lower court had given instructions that led the jury to improperly value the benefit of the girlfriend's services to the company rather than determine the value of the services under quantum meruit. The court held that the girlfriend had attempted to show the existence of an implied-in-fact contract that would have given her some equity in the company but the jury instructions did not accurately convey the law. Further, the court held that there could be no breach of fiduciary duty since the jury found there was no contract that the boyfriend would share the business with the girlfriend.