Palmer v. Gregg

In Palmer v. Gregg (1967) 65 Cal.2d 657, the plaintiff sought a quantum meruit recovery against a decedent's estate arising out of the care she provided to decedent prior to his death. While the Supreme Court agreed she was entitled to recover the value of the services she rendered, it rejected her claim that the expense she incurred for a gardener to maintain her own home for the period she was with the decedent should be allowed as well: "The facts of the present case suggest no exception to the general rule: plaintiff's personal gardening expenses conferred no direct benefit on decedent, and accordingly cannot be recovered in this action." (Id. at pp. 660-661.)