Raymond Campbell, D/B/A Ray's Photographic Studio v. Tennessee Valley Authority, Defendant-Third Party v. Earl Daniel, Third Party
421 F.2d 293 · Court of Appeals for the Third Circuit · 1970
Facts
Raymond Campbell entered an oral agreement with an unauthorized TVA agent to microfilm technical journals for $30,240. Campbell delivered the 336 rolls of microfilm, and the original journals were destroyed, but TVA returned the film after two months, refusing payment due to the agent's lack of authority. Campbell then sued TVA in quantum meruit after his initial express contract claim was dismissed.
Issue
What is the proper measure of recovery in a quantum meruit action against a federal government agency when goods or services are provided under an unauthorized contract: the fair market value of the goods or services provided, or the reasonable value of the benefit actually realized by the government?
Holding
The court affirmed the District Court's judgment, holding that Campbell was entitled to recover the fair market value of the microfilm, which was $30,240, because the actual benefit to TVA was difficult to prove.
Rule
In quantum meruit claims against the government, where the actual benefit to the government is difficult to quantify (e.g., the value of library materials), the measure of recovery is the fair market value of the goods or services provided, serving as a "rule-of-thumb" to prevent unjust enrichment.
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