quantum meruit claim (District of Columbia) · Go Syfert
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quantum meruit claim in District of Columbia

10 District of Columbia opinions name it 1 courts 1984–2026 1 in the last five years

The cases below were cited by District of Columbia 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 (10)

CaseFollowedCited
Vereen v. Claybornegreen
dc · 1993 · cited in 2 District of Columbia opinions naming this issue, 2018–2026
2 sentences

2026See Vereen v. Clayborne, 623 A.2d 1190, 1194 (D.C. 1993) (“This particular quantum meruit analysis is more commonly known as a theory of unjust enrichment.”); see also Boyd v. Kilpatrick Townsend & Stockton, 164 A.3d 72 , 85 (D.C. 2017) (McLeese, J., concurring) (discussing the imprecisions in what a “quantum meruit” claim covers). 14 acknowledges the implied contract he alleges could not be performed within one year, so that the statute of frauds presumptively bars its enforcement, but that the “part performance” exception applies to rescue this claim as well.

2018See, e.g. , News World Commc'ns, Inc. v. Thompsen , 878 A.2d 1218 , 1223 (D.C. 2005) ("[T]he essence of a quantum meruit claim is not the plaintiff's expectancy of payment, but the unjust enrichment of the defendant ....") (ellipses and internal quotation marks omitted); Vereen v. Clayborne , 623 A.2d 1190 , 1194 (D.C. 1993) ("This particular quantum meruit analysis is more commonly known as a theory of unjust enrichment."). *834 We are aware of no case, from this court or any other, that has found a claim sounding in unjust enrichment to be a liquidated debt for purposes of determining whethe

22
Hancock v. Bureau of National Affairs, Inc.green
dc · 1994 · cited in 2 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005See Hancock v. Bureau of Nat'l Affairs, 645 A.2d 588, 590-91 (D.C. 1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem'l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). [10] Although there are references to the $20,000.00 check in the record, a copy of the actual check is not part of the record.

2005See Hancock v. Bureau of Nat’l Affairs, 645 A.2d 588, 590-91 (D.C.1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem’l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). .

22
Hinch v. Lucy Webb Hayes National Training School for Deaconessesgreen
dc · 2003 · cited in 2 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005See Hancock v. Bureau of Nat'l Affairs, 645 A.2d 588, 590-91 (D.C. 1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem'l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). [10] Although there are references to the $20,000.00 check in the record, a copy of the actual check is not part of the record.

2005See Hancock v. Bureau of Nat’l Affairs, 645 A.2d 588, 590-91 (D.C.1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem’l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). .

22
John W. Boyd, Jr. v. Kilpatrick Townsend & Stocktongreen
dc · 2017 · cited in 1 District of Columbia opinions naming this issue, 2026–2026
1 sentence

2026See Vereen v. Clayborne, 623 A.2d 1190, 1194 (D.C. 1993) (“This particular quantum meruit analysis is more commonly known as a theory of unjust enrichment.”); see also Boyd v. Kilpatrick Townsend & Stockton, 164 A.3d 72 , 85 (D.C. 2017) (McLeese, J., concurring) (discussing the imprecisions in what a “quantum meruit” claim covers). 14 acknowledges the implied contract he alleges could not be performed within one year, so that the statute of frauds presumptively bars its enforcement, but that the “part performance” exception applies to rescue this claim as well.

11
News World Communications, Inc. v. Thompsengreen
dc · 2005 · cited in 1 District of Columbia opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , News World Commc'ns, Inc. v. Thompsen , 878 A.2d 1218 , 1223 (D.C. 2005) ("[T]he essence of a quantum meruit claim is not the plaintiff's expectancy of payment, but the unjust enrichment of the defendant ....") (ellipses and internal quotation marks omitted); Vereen v. Clayborne , 623 A.2d 1190 , 1194 (D.C. 1993) ("This particular quantum meruit analysis is more commonly known as a theory of unjust enrichment."). *834 We are aware of no case, from this court or any other, that has found a claim sounding in unjust enrichment to be a liquidated debt for purposes of determining whethe

2018See, e.g. , News World Commc'ns, Inc. v. Thompsen , 878 A.2d 1218 , 1223 (D.C. 2005) ("[T]he essence of a quantum meruit claim is not the plaintiff's expectancy of payment, but the unjust enrichment of the defendant ....") (ellipses and internal quotation marks omitted); Vereen v. Clayborne , 623 A.2d 1190 , 1194 (D.C. 1993) ("This particular quantum meruit analysis is more commonly known as a theory of unjust enrichment."). *834 We are aware of no case, from this court or any other, that has found a claim sounding in unjust enrichment to be a liquidated debt for purposes of determining whethe

11
Lamajak, Inc. v. Frazingreen
texapp · 2007 · cited in 1 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017See Lamajak, Inc. v. Frazin, 230 S.W.3d 786, 796 (Tex. App. 2007) (“Frazin‟s services were not of such a nature that there was an implied condition of payment at certain intervals after which limitations would begin to run.

2017See Lamajak, Inc. v. Frazin, 230 S.W.3d 786, 796 (Tex. App.-Dallas 2007) (“Frazin’s services were not of such a nature that there was an implied condition of payment at certain intervals after which limitations would begin to run.

11
District of Columbia v. Campbellgreen
dc · 1990 · cited in 1 District of Columbia opinions naming this issue, 2008–2008
1 sentence

2008Indeed, in District of Columbia v. Campbell, 580 A.2d 1295, 1301-02 (D.C.1990), this court held that a plaintiffs negligence claim failed for lack of notice, even where he asserted a quantum meruit claim.

11
Henry S. Bloomgarden v. Charles B. Coyergreen
cadc · 1973 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
2 sentences

1993“A quasi-contract ... is not a contract at all, but a duty thrust under certain conditions upon one party to requite another in order to avoid the former’s unjust enrichment.” Bloomgarden, 156 U.S.App.D.C. at 116 , 479 F.2d at 208 (footnote omitted); see also 4934, Inc. v. District of Columbia Dep’t of Employment Servs., 605 A.2d 50, 55 (D.C.1992); Brown, 524 A.2d at 1186 ; supra note 2.

1993“A quasi-contract ... is not a contract at all, but a duty thrust under certain conditions upon one party to requite another in order to avoid the former’s unjust enrichment.” Bloomgarden, 156 U.S.App.D.C. at 116 , 479 F.2d at 208 (footnote omitted); see also 4934, Inc. v. District of Columbia Dep’t of Employment Servs., 605 A.2d 50, 55 (D.C.1992); Brown, 524 A.2d at 1186 ; supra note 2.

11
4934, Inc. v. District of Columbia Department of Employment Servicesgreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993“A quasi-contract ... is not a contract at all, but a duty thrust under certain conditions upon one party to requite another in order to avoid the former’s unjust enrichment.” Bloomgarden, 156 U.S.App.D.C. at 116 , 479 F.2d at 208 (footnote omitted); see also 4934, Inc. v. District of Columbia Dep’t of Employment Servs., 605 A.2d 50, 55 (D.C.1992); Brown, 524 A.2d at 1186 ; supra note 2.

11
In Re Conservatorship for Richgreen
dc · 1975 · cited in 1 District of Columbia opinions naming this issue, 1984–1984
2 sentences

1984In re Rich, 337 A.2d 764, 766 (D.C.1975).

1984In re Rich, 337 A.2d 764, 766 (D.C.1975).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Weakley v. Burnham Corp. green
dc · 2005
2 sentences

2005See Hancock v. Bureau of Nat'l Affairs, 645 A.2d 588, 590-91 (D.C. 1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem'l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). [10] Although there are references to the $20,000.00 check in the record, a copy of the actual check is not part of the record.

2005See Hancock v. Bureau of Nat’l Affairs, 645 A.2d 588, 590-91 (D.C.1994); see also Hinch v. Lucy Webb Hayes Nat'l Training Sch. for Deaconesses & Missionaries Conducting Sibley Mem’l Hosp., 814 A.2d 926, 928-31 (D.C.2003); Weakley v. Burnham Corp., 871 A.2d 1167 , 1177-78 n. 10 (D.C.2005). .

22005–2005
Zanders v. Reid green
dc · 2009
1 sentence

2026This argument fails for the same reasons it failed to save Farooqui’s breach of contract claim: Whatever partial performance occurred here, it was not “unequivocal evidence of the alleged agreement.” Zanders, 980 A.2d at 1102 .

12026–2026
Cunningham & Associates v. Dugan green
dc · 1996
2 sentences

2017Contrary to the court‟s suggestion, ante at 18, the principle that the statute of limitations on a quantum-meruit claim does not begin to run until payment would reasonably be expected is supported rather than undermined by our decision in 29 Cunningham & Assocs. v. Dugan, 909 A.2d 1001 (1996).

2017Contrary to the court’s suggestion, ante at 81, the principle that the statute of limitations on a quantum-meruit claim does not begin to run until payment would reasonably be expected is supported rather than undermined by our decision in Cunningham & Assocs. v. Dugan, 909 A.2d 1001 (1996).

12017–2017
Zic v. Italian Government Travel Office green
ilnd · 2001
1 sentence

2005Id.

12005–2005
Brown v. Brown green
dc · 1987
1 sentence

1993“A quasi-contract ... is not a contract at all, but a duty thrust under certain conditions upon one party to requite another in order to avoid the former’s unjust enrichment.” Bloomgarden, 156 U.S.App.D.C. at 116 , 479 F.2d at 208 (footnote omitted); see also 4934, Inc. v. District of Columbia Dep’t of Employment Servs., 605 A.2d 50, 55 (D.C.1992); Brown, 524 A.2d at 1186 ; supra note 2.

11993–1993
Giant Food, Inc. v. JACK I. BENDER, ETC. green
dc · 1979
2 sentences

1990Bender & Sons, 399 A.2d 1293 (D.C.1979), while holding that the plaintiffs liquidated claim was not converted into an unliquidated debt by the defendant’s unliquidated counterclaim, we emphasized that we were not dealing with “a case in which substantial performance of a contract or a quantum meruit claim was at issue.” Id. at 1302 .

1990Bender & Sons, 399 A.2d 1293 (D.C.1979), while holding that the plaintiffs liquidated claim was not converted into an unliquidated debt by the defendant’s unliquidated counterclaim, we emphasized that we were not dealing with “a case in which substantial performance of a contract or a quantum meruit claim was at issue.” Id. at 1302 .

11990–1990

Where else courts name it

TX 170 (1941–2026) CA 57 (1979–2026) NY 55 (1931–2026) IL 52 (1979–2026) MO 30 (1933–2024) PA 29 (1950–2025) GA 28 (1973–2025) LA 28 (1973–2021) NJ 27 (1979–2026) CT 26 (1982–2019) OR 23 (1983–2025) OH 20 (1992–2025) SC 20 (1926–2024) MA 18 (1980–2026) MS 17 (1984–2026) FL 17 (1982–2025) ME 16 (1994–2024) WA 16 (1930–2026) CO 15 (1984–2026) TN 15 (1983–2026) UT 14 (1988–2015) NC 12 (1984–2022) VA 11 (1986–2012) KY 11 (2000–2026) DC 10 (1984–2026) IN 8 (1914–2024) DE 7 (2019–2025) MI 7 (1975–2021) NV 7 (1978–2017) WI 6 (2019–2026) NE 6 (1921–2019) AL 6 (1907–2025) AR 5 (1922–1997) ND 5 (1989–2016) AZ 5 (1971–2015) MD 4 (1998–2015) VT 4 (2013–2026) IA 4 (1908–2020) NM 4 (1980–2011) SD 4 (1994–2026) HI 3 (1914–2024) MN 3 (1924–2016) WY 3 (1989–2022) KS 3 (1990–2021) NH 2 (1983–1999) ID 2 (1897–2002) RI 2 (1992–2021)

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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