Washington
How Britton v. Turner applies in Washington: state-specific rules, key cases, and bar exam notes for Contracts.
Washington law follows the general principle of quantum meruit, which allows for compensation for work performed even when a contract may be unenforceable. This aligns with the idea of preventing unjust enrichment, a key tenet derived from Britton v. Turner.
In Washington, if a party has partially performed under a contract, they may recover for the value of the work performed even if the contract is not fully enforceable, provided there was a good faith basis for the work.
The court held that a party may recover for reliance damages if they acted in good faith under a purported agreement.
The court affirmed recovery for a partially performed contract based on the reasonable value of services rendered.
The ruling emphasized that a plaintiff can seek quantum meruit recovery when a specific contract is breached but substantial performance has occurred.
Washington's application reflects a broader interpretation of quantum meruit compared to federal standards, which can sometimes require a stricter adherence to the terms of a contract before awarding compensation. Unlike some federal circuits, Washington courts more readily enforce recovery for partially performed work to prevent unjust enrichment.
Principles from Britton v. Turner, particularly regarding quantum meruit and unjust enrichment, are often tested in Washington's bar exam in the context of contract law.