Artisan Builders, Inc. v. Jang

The Pennsylvania Superior Court worked to clarify the difference between quantum meruit and unjust enrichment in the context of this residential renovation dispute. The homeowner hired a contractor to work on his home. He was aware of the work being performed, and it was performed with the homeowner’s permission. But before the job was complete, the homeowner fired the contractor. The contractor sued, alleging quantum meruit, unjust enrichment, and breach of contract. But the lower court sustained preliminary objections to all claims other than quantum meruit. The Superior Court explained that quantum meruit is an equitable remedy, which is defined as much as deserved and measures compensation under an implied contract to pay compensation as the reasonable value of services rendered. And unjust enrichment is the retention of a benefit conferred by another, without offering compensation, in circumstances where compensation is reasonably expected, for which the beneficiary must make restitution. So quantum meruit involves recovery for services or materials provided under an implied contract. Unjust enrichment describes recovery for the value of the benefit retained when there is no contractual relationship, but when the law compels the performance of a legal and moral duty to pay based on fairness and justice. The Court held that the lower court erred when it concluded that the contractor’s recovery must be measured by the benefit to the homeowner.

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