§12.7 Quantum Meruit

• Jurisdiction: Washington

§12.7 QUANTUM MERUIT

A contractor may seek recovery under the doctrine of quantum meruit—literally "as much as ... deserved"—when (1) "one party's performance occurs in the absence of a contract"; or (2) "substantial change not within contemplation of the parties occurs with a resulting benefit to one party and expense to the other." Heaton v. Imus, 93 Wn.2d 249, 254, 608 P.2d 631 (1980) (quoting Dravo Corp. v. L.W. Moses Co., 6 Wn. App. 74, 91, 492 P.2d 1058 (1971)); see also Hensel Phelps Constr. Co. v. King County, 57 Wn. App. 170, 174, 787 P.2d 58 (1990) (citing Bignold v. King County, 65 Wn.2d 817, 399 P.2d 611 (1965)). "[A] finding that the contractor should have...