quantum meruit claim (Tennessee) · Go Syfert
← Tennessee issues

quantum meruit claim in Tennessee

14 Tennessee opinions name it 1 courts 1983–2026 2 in the last five years

The cases below were cited by Tennessee 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 (13)

CaseFollowedCited
Mitch Grissim & Associates v. Blue Cross & Blue Shield of Tennesseegreen
tennctapp · 2002 · cited in 3 Tennessee opinions naming this issue, 2005–2026
2 sentences

2026“The measure of damages for a quantum meruit claim is the actual value of the services provided.” In re Est. of Marks, 187 S.W.3d 21, 32 (Tenn. Ct. App. 2005) (citing Mitch Grissim & Assocs. v. Blue Cross Blue Shield of Tenn., 114 S.W.3d 531, 537 (Tenn. Ct. App. 2002)).

2026The party seeking to recover under a quantum meruit theory must therefore “present some proof regarding the reasonable value of the services rendered.” Id. (citing CPB Mgmt., Inc. v. Everly, 939 S.W.2d 78, 81 (Tenn. Ct. App. 1996)).

33
In Re Estate of Marksgreen
tennctapp · 2005 · cited in 2 Tennessee opinions naming this issue, 2025–2026
2 sentences

2026“The measure of damages for a quantum meruit claim is the actual value of the services provided.” In re Est. of Marks, 187 S.W.3d 21, 32 (Tenn. Ct. App. 2005) (citing Mitch Grissim & Assocs. v. Blue Cross Blue Shield of Tenn., 114 S.W.3d 531, 537 (Tenn. Ct. App. 2002)).

2025In re Est. of Marks, 187 S.W.3d 21, 32 (Tenn. Ct. App. 2005) (citing Mitch Grissim & Assocs. v. Blue Cross Blue Shield of Tenn., 114 S.W.3d 531, 537 (Tenn. Ct. App. 2002)).

22
Doe v. HCA Health Services of Tennessee, Inc.green
tenn · 2001 · cited in 2 Tennessee opinions naming this issue, 2018–2018
2 sentences

2018Doe v. HCA Health Servs. of Tennessee, Inc., 46 S.W.3d 191, 197-98 (Tenn. 2001) (internal quotation and citations omitted).

2018Doe v. HCA Health Servs. of Tennessee, Inc., 46 S.W.3d 191, 197-98 (Tenn. 2001) (internal quotation and citations omitted).

22
Paschall's, Inc. v. Doziergreen
tenn · 1966 · cited in 3 Tennessee opinions naming this issue, 1983–2018
2 sentences

2018They also met with prospective players and families to discuss their joining the organization. 3 Although this case deals with a quantum meruit claim, courts have held that “[a]ctions brought upon theories of unjust enrichment, quasi contract, contracts implied in law, and quantum meruit are essentially the same.” Paschall’s, Inc., 407 S.W.2d at 154 . -8- Mr. Cole used his own vehicle for thousands of miles of travel for East Coast Grays’ business during 2010 and 2011, and Mr. Caruso often traveled with him.

2017The confusion between these two concepts began over fifty years ago, when the Tennessee Supreme Court stated that “[a]ctions brought upon theories of unjust enrichment, quasi contract, contracts implied in law, and quantum meruit are essentially the same.” Paschall’s, Inc. v. Dozier, 407 S.W.2d 150, 154 (Tenn. 1966).

13
Castelli v. Liengreen
tennctapp · 1995 · cited in 2 Tennessee opinions naming this issue, 2001–2018
2 sentences

2018Compare Castelli, 910 S.W.2d at 427 (outlining the five elements needed to establish a quantum meruit claim), with Freeman Indus., LLC., 172 S.W.3d at 525 (outlining three elements needed to establish an unjust enrichment claim).

2001In Castelli v. Lien, 910 S.W.2d 420 (Tenn. Ct. App. 1995), the middle section of this court discussed in detail the doctrine of quantum meruit.

12
CPB Management., Inc. v. Everlygreen
tennctapp · 1996 · cited in 1 Tennessee opinions naming this issue, 2026–2026
1 sentence

2026The party seeking to recover under a quantum meruit theory must therefore “present some proof regarding the reasonable value of the services rendered.” Id. (citing CPB Mgmt., Inc. v. Everly, 939 S.W.2d 78, 81 (Tenn. Ct. App. 1996)).

11
Bean v. Beangreen
tennctapp · 2000 · cited in 1 Tennessee opinions naming this issue, 2020–2020
1 sentence

2020Newcomb v. Kohler Co., 222 S.W.3d 368, 401 (Tenn. Ct. App. 2006) (failure “to cite to any authority or to construct an argument regarding [a] position on appeal” constitutes a waiver of the issue); Bean v. Bean, 40 S.W.3d 52 , 55–56 (Tenn. Ct. App. 2000) (“Courts have routinely held that the failure to make appropriate references to the record and to cite relevant authority in the argument section of the brief as required by Rule 27(a)(7) constitutes a waiver of the issue.”). 370 S.W.3d 347, 355 (Tenn. Ct. App. 2011). 7 been the rule since Tate v. Camp, that a forfeiture provision will not be

11
Charlotte Scott Forbess v. Michael E. Forbessgreen
tennctapp · 2011 · cited in 1 Tennessee opinions naming this issue, 2020–2020
1 sentence

2020Newcomb v. Kohler Co., 222 S.W.3d 368, 401 (Tenn. Ct. App. 2006) (failure “to cite to any authority or to construct an argument regarding [a] position on appeal” constitutes a waiver of the issue); Bean v. Bean, 40 S.W.3d 52 , 55–56 (Tenn. Ct. App. 2000) (“Courts have routinely held that the failure to make appropriate references to the record and to cite relevant authority in the argument section of the brief as required by Rule 27(a)(7) constitutes a waiver of the issue.”). 370 S.W.3d 347, 355 (Tenn. Ct. App. 2011). 7 been the rule since Tate v. Camp, that a forfeiture provision will not be

11
Newcomb v. Kohler Co.green
tennctapp · 2006 · cited in 1 Tennessee opinions naming this issue, 2020–2020
1 sentence

2020Newcomb v. Kohler Co., 222 S.W.3d 368, 401 (Tenn. Ct. App. 2006) (failure “to cite to any authority or to construct an argument regarding [a] position on appeal” constitutes a waiver of the issue); Bean v. Bean, 40 S.W.3d 52 , 55–56 (Tenn. Ct. App. 2000) (“Courts have routinely held that the failure to make appropriate references to the record and to cite relevant authority in the argument section of the brief as required by Rule 27(a)(7) constitutes a waiver of the issue.”). 370 S.W.3d 347, 355 (Tenn. Ct. App. 2011). 7 been the rule since Tate v. Camp, that a forfeiture provision will not be

11
Freeman Industries, LLC v. Eastman Chemical Co.green
tenn · 2005 · cited in 1 Tennessee opinions naming this issue, 2018–2018
1 sentence

2018Compare Castelli, 910 S.W.2d at 427 (outlining the five elements needed to establish a quantum meruit claim), with Freeman Indus., LLC., 172 S.W.3d at 525 (outlining three elements needed to establish an unjust enrichment claim).

11
Myrtle Beach Hospital, Inc. v. City of Myrtle Beachgreen
sc · 2000 · cited in 1 Tennessee opinions naming this issue, 2017–2017
1 sentence

2017For example, in Ridgelake Apartments v. Harpeth Valley Utilities Dist. of Davidson & Williamson Cntys., No. M2003- 02485-COA-R3-CV, 2005 WL 831594 (Tenn. Ct. App. Apr. 8, 2005), this Court quoted favorably an Opinion from the South Carolina Supreme Court in which a quantum meruit claim was defined as a claim based upon a contract “implied in fact.” Id. at *9 (quoting Myrtle Beach Hosp., Inc. v. City of Myrtle Beach, 532 S.E.2d 868, 872 (S.C. 2000)).

11
Lawler v. Zapletalgreen
tennctapp · 1984 · cited in 1 Tennessee opinions naming this issue, 2005–2005
1 sentence

2005Mitch Grissim & Assocs. v. Blue Cross Blue Shield of Tenn., 114 S.W.3d 531, 537 (Tenn.Ct.App.2002); Lawler v. Zapletal, 679 S.W.2d 950, 955 (Tenn.Ct.App.1984).

11
Chedester v. Phillipsgreen
tenn · 1982 · cited in 1 Tennessee opinions naming this issue, 2001–2001
1 sentence

2001See Chedester v. Phillips, 640 S.W.2d 207, 208 (Tenn. 1982); Farmer v. -4- Farmer, 528 S.W.2d at 542 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
White v. McBride green
tenn · 1996
1 sentence

2012Id.

12012–2012
Farmer v. Farmer green
tenn · 1975
1 sentence

2001See Chedester v. Phillips, 640 S.W.2d 207, 208 (Tenn. 1982); Farmer v. -4- Farmer, 528 S.W.2d at 542 .

12001–2001
Murray v. Grissim green
idaho · 1956
1 sentence

2001To support his position, Donovan relies on Murray v. Grissim, 290 S.W.2d 888 (Tenn. Ct. App. 1956).

12001–2001
Barr v. Plastic Surgery Consultants, Ltd. green
moctapp · 1988
1 sentence

1999Thus, the quantum meruit claim was at issue w hen the eviden ce wa s admitt ed. See Barr v. Plastic Sur gery Co nsultants, 760 S.W.2d 585 (Mo.Ct.App. 1988) (evidence relating to claim disposed of by directed verdict was relevant and material at trial as issue was still viable).

11999–1999

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.

← Caselaw search · G Cite Topics · Brief Check