Quantum Valebant: Recovering Goods’ Value Without Contracts
Quantum Valebant
Quantum valebant is a legal principle allowing a party to recover the reasonable value of goods provided when no enforceable contract exists. Meaning “as much as they were worth” in Latin, it ensures fair compensation when goods have been delivered and accepted, but no price was agreed upon or the contract is unenforceable.
Historically part of common law assumpsit, quantum valebant now falls under quasi-contract or unjust enrichment, preventing recipients from unfairly benefiting from unpaid goods.
When Does Quantum Valebant Apply?
To claim quantum valebant, the provider must show:
- The defendant is indebted to the plaintiff in a specific sum;
- The consideration for this debt, i.e., goods sold and delivered to the defendant;
- Nonpayment of the debt by the defendant.
Courts assess value based on market rates, quality, and customary pricing.
Example of Quantum Valebant
A supplier delivers custom furniture to a business, which accepts and uses it. Later, a dispute arises over pricing, and the contract is found unenforceable due to a missing signature. The supplier can sue under quantum valebant, seeking fair market value for the furniture.
Quantum Valebant vs. Quantum Meruit
Quantum valebant applies to goods, while quantum meruit (“as much as he has deserved”) applies to services provided without an enforceable contract. Both prevent unjust enrichment by ensuring fair compensation.
Conclusion
Quantum valebant upholds fairness in commerce, ensuring those who provide goods are paid even without a binding contract. It reinforces trust in transactions while preventing one party from profiting unfairly at another’s expense.
