quantum meruit claim (Washington) · Go Syfert
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quantum meruit claim in Washington

16 Washington opinions name it 2 courts 1930–2026 1 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
Young v. Younggreen
wash · 2008 · cited in 2 Washington opinions naming this issue, 2014–2014
2 sentences

2014The trial court further explained that the providers filed their complaint before this court's decision in Young v. Young, 164 Wn.2d 477 , 191 P.3d 1258 (2008), drew a line between an unjust enrichment claim, or a claim premised on a contract implied-in-law, and a quantum meruit claim, or a claim premised on a contract implied-in-fact.

2014The trial court further explained that the providers filed their complaint before this court’s decision in Young v. Young, 164 Wn.2d 477 , 191 P.3d 1258 (2008), drew a line between an unjust enrichment claim, or a claim premised on a contract implied-in-law, and a quantum meruit claim, or a claim premised on a contract implied-in-fact.

22
Kimball v. Public Utility District No. 1green
wash · 1964 · cited in 2 Washington opinions naming this issue, 1983–1986
2 sentences

1986Those factors, which are similar to those used to determine the reasonable value of professional services in a quantum meruit claim, Kimball v. PUD 1, 64 Wn.2d 252, 257 , 391 P.2d 205 (1964), are: (B) . . .

1986Those factors, which are similar to those used to determine the reasonable value of professional services in a quantum meruit claim, Kimball v. PUD 1, 64 Wn.2d 252, 257 , 391 P.2d 205 (1964), are: (B) . . .

12
Hansen v. Wightmangreen
washctapp · 1975 · cited in 1 Washington opinions naming this issue, 1983–1983
1 sentence

1983See Hansen v. Wightman, 14 Wn.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (18)

CaseCitedYears
Heaton v. Imus green
wash · 1980
2 sentences

2018Pitell also cites to Heaton v. Imus , 21 Wash. App. 914 , 587 P.2d 602 (1978), reversed on other grounds , 93 Wash.2d 249 , 608 P.2d 631 (1980), but that case merely states that the absence of a price term requires a quantum meruit analysis.

2018Pitell also cites to Heaton v. Imus , 21 Wash. App. 914 , 587 P.2d 602 (1978), reversed on other grounds , 93 Wash.2d 249 , 608 P.2d 631 (1980), but that case merely states that the absence of a price term requires a quantum meruit analysis.

22018–2018
Heaton v. Imus green
washctapp · 1978
2 sentences

2018Pitell also cites to Heaton v. Imus , 21 Wash. App. 914 , 587 P.2d 602 (1978), reversed on other grounds , 93 Wash.2d 249 , 608 P.2d 631 (1980), but that case merely states that the absence of a price term requires a quantum meruit analysis.

2018Pitell also cites to Heaton v. Imus , 21 Wash. App. 914 , 587 P.2d 602 (1978), reversed on other grounds , 93 Wash.2d 249 , 608 P.2d 631 (1980), but that case merely states that the absence of a price term requires a quantum meruit analysis.

22018–2018
Failor's Pharmacy v. Department of Social & Health Services green
wash · 1994
2 sentences

2014In turn, it further suggested that the contract at issue was void and recognized that a "party is entitled to recover for losses on the void contract under the doctrine of quantum meruit." Id. at 499 . 8 The contract at issue here is not void.

2014In turn, it further suggested that the contract at issue was void and recognized that a “party is entitled to recover for losses on the void contract under the doctrine of quantum meruit.” Id. at 499 . 11 ¶88 The contract at issue here is not void.

22014–2014
Young v. Young green
wash · 2008
2 sentences

2014The trial court further explained that the providers filed their complaint before this court's decision in Young v. Young, 164 Wn.2d 477 , 191 P.3d 1258 (2008), drew a line between an unjust enrichment claim, or a claim premised on a contract implied-in-law, and a quantum meruit claim, or a claim premised on a contract implied-in-fact.

2014The trial court further explained that the providers filed their complaint before this court’s decision in Young v. Young, 164 Wn.2d 477 , 191 P.3d 1258 (2008), drew a line between an unjust enrichment claim, or a claim premised on a contract implied-in-law, and a quantum meruit claim, or a claim premised on a contract implied-in-fact.

22014–2014
Bailie Communications, Ltd. v. Trend Business Systems, Inc. green
washctapp · 1991
2 sentences

2007Sys., Inc., 61 Wash.App. 151, 159-60 , 810 P.2d 12 (1991). ¶ 44 Unjust enrichment encompasses the doctrine of quantum meruit.

2007App. 151, 159-60 , 810 P.2d 12 (1991). ¶44 Unjust enrichment encompasses the doctrine of quantum meruit.

22007–2007
Bort v. Parker green
washctapp · 2002
2 sentences

2007Bort v. Parker, 110 Wash.App. 561, 580-81 , 42 P.3d 980 (2002).

2007Bort v. Parker, 110 Wn.

22007–2007
Dragt v. Dragt/DeTray, LLC green
washctapp · 2007
2 sentences

2026“Unjust enrichment encompasses the doctrine of quantum meruit.” Id. at 576-77 .

2026The doctrine of quantum meruit provides a remedy for restitution, allowing a party to recover the value of “the benefit conferred upon the defendant.” Id. 10 No. 40642-3-III Johnston v. Peach Appreciated Value of the Property The Johnstons contend the trial court erred in not awarding them the entirety of the Property’s full appreciated value, resulting in Ms. Peach being unjustly enriched.

12026–2026
Hensel Phelps Construction Co. v. King County green
washctapp · 1990
1 sentence

2020The trial court stated, “I think 27Flatiron argues this court rejected an analogous argument in Hensel Phelps Const. Co. v. King County, 57 Wn.

12020–2020
Marvin v. Marvin green
cal · 1976
2 sentences

2019Marvin v. Marvin, 18 Cal.3d 660, 665 , 557 P.2d 106 (1976).

2019Marvin v. Marvin, 18 Cal.3d 660, 665 , 557 P.2d 106 (1976).

12019–2019
Kofmehl v. Baseline Lake, LLC green
wash · 2013
2 sentences

2018Kofmehl v. Baseline Lake, LLC, 177 Wn.2d 584, 594 , 305 P.3d 230 (2013).

2018Kofmehl v. Baseline Lake, LLC, 177 Wn.2d 584, 594 , 305 P.3d 230 (2013).

12018–2018
Western Washington Corp. v. Ferrellgas, Inc. green
washctapp · 2000
2 sentences

2018These cases are not helpful. ¶ 16 Additionally, Pitell cites to Western Washington Corp. of Seventh-Day Adventists v. Ferrellgas, Inc. , 102 Wash. App. 488 , 7 P.3d 861 (2000), for the proposition that external provisions to an agreement must be incorporated by clear and unequivocal reference.

2018These cases are not helpful. ¶ 16 Additionally, Pitell cites to Western Washington Corp. of Seventh-Day Adventists v. Ferrellgas, Inc. , 102 Wash. App. 488 , 7 P.3d 861 (2000), for the proposition that external provisions to an agreement must be incorporated by clear and unequivocal reference.

12018–2018
Blaney v. International Ass'n of MacHinists green
wash · 2004
1 sentence

2014"An erroneous jury instruction is harmless if it is 'not prejudicial . . . and in no way affected the final outcome of the case.'" Blanev v. Int'l Assoc, of Machinists & Aerospace Workers, Dist. 160. 151 Wn.2d 203, 211 , 87 P.3d 757 (2004) (quoting State v. Britton, 27 Wn.2d 336, 341 , 178 P.2d 341 (1947)).

12014–2014
Blaney v. International Ass'n of Machinists & Aerospace Workers green
wash · 2004
1 sentence

2014"An erroneous jury instruction is harmless if it is 'not prejudicial . . . and in no way affected the final outcome of the case.'" Blanev v. Int'l Assoc, of Machinists & Aerospace Workers, Dist. 160. 151 Wn.2d 203, 211 , 87 P.3d 757 (2004) (quoting State v. Britton, 27 Wn.2d 336, 341 , 178 P.2d 341 (1947)).

12014–2014
State v. Britton green
wash · 1947
2 sentences

2014"An erroneous jury instruction is harmless if it is 'not prejudicial . . . and in no way affected the final outcome of the case.'" Blanev v. Int'l Assoc, of Machinists & Aerospace Workers, Dist. 160. 151 Wn.2d 203, 211 , 87 P.3d 757 (2004) (quoting State v. Britton, 27 Wn.2d 336, 341 , 178 P.2d 341 (1947)).

2014"An erroneous jury instruction is harmless if it is 'not prejudicial . . . and in no way affected the final outcome of the case.'" Blanev v. Int'l Assoc, of Machinists & Aerospace Workers, Dist. 160. 151 Wn.2d 203, 211 , 87 P.3d 757 (2004) (quoting State v. Britton, 27 Wn.2d 336, 341 , 178 P.2d 341 (1947)).

12014–2014
McGee Guest Home, Inc. v. Department of Social & Health Services neutral
washctapp · 1999
1 sentence

2014See Br. ofResp'ts Rekhter, et al. at 35-36 & n.15; Br. ofResp'ts SEIU Healthcare 775NW & Cindy Weens at 45-50. 9 The providers argue that a "Failor's Pharmacy remedy has been applied expressly to other DSHS failures to follow federal law." Br. ofResp'ts Rekhter, et al. at 36 (citing McGee Guest Home v. Dep 't ofSoc. & Health Servs., 96 Wn.

12014–2014
Bort v. Parker green
washctapp · 2002
1 sentence

2007Bort v. Parker, 110 Wash.App. 561, 580-81 , 42 P.3d 980 (2002).

12007–2007
Noel v. Cole green
wash · 1982
1 sentence

1994Noel, 98 Wn.2d at 381 .

11994–1994
Green v. Okanogan County green
wash · 1910
2 sentences

1930In the case of Green v. Okanogan County, 60 Wash. 309 , 111 Pac. 226 , it appeared that the county commissioners had let a contract for the construction of a bridge under such circumstances that the contract was void.

1930In the case of Green v. Okanogan County, 60 Wash. 309 , 111 Pac. 226 , it appeared that the county commissioners had let a contract for the construction of a bridge under such circumstances that the contract was void.

11930–1930

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.84.330 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 169 (1941–2026) CA 56 (1979–2026) NY 52 (1931–2026) IL 52 (1979–2025) PA 30 (1950–2025) MO 29 (1967–2024) GA 28 (1973–2025) LA 28 (1973–2021) NJ 27 (1979–2026) CT 24 (1982–2019) OR 23 (1983–2025) SC 20 (1926–2024) OH 19 (1992–2024) MA 18 (1980–2026) FL 17 (1982–2025) MS 16 (1984–2023) WA 16 (1930–2026) ME 16 (1994–2024) CO 14 (1984–2026) UT 14 (1988–2015) TN 14 (1983–2026) VA 11 (1986–2012) NC 10 (1984–2021) DC 9 (1984–2018) IN 8 (1914–2024) NV 7 (1978–2017) KY 7 (2000–2026) MI 6 (1975–2018) WI 6 (2019–2026) NE 5 (1988–2019) AZ 5 (1971–2015) AR 5 (1922–1997) DE 5 (2020–2025) ND 5 (1989–2016) AL 5 (1907–2025) MD 4 (1998–2015) SD 4 (1994–2026) IA 4 (1908–2020) NM 4 (1980–2011) WY 3 (1989–2022) VT 3 (2013–2024) MN 3 (1924–2016) HI 3 (1914–2024) KS 3 (1990–2021) NH 2 (1983–1999) ID 2 (1897–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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