In Huskinson & Brown, LLP v. Wolf (2004) 32 Cal.4th 453, the California Supreme Court stated: "Quantum meruit refers to the well-established principle that 'the law implies a promise to pay for services performed under circumstances disclosing that they were not gratuitously rendered.'" Therefore, according to the Huskinson court, a party seeking to prevail on a quantum meruit claim for services provided must establish that "the services were rendered under some understanding or expectation of both parties that compensation therefor was to be made." (Ibid.)