Kearns v. Andree
In Kearns v. Andree, 107 Conn. 181, 139 A. 695 (Conn. 1928), the plaintiff was able to recover for the value of services made to improve a building that the defendant intended to purchase but ultimately did not.
Although the defendant did not actually benefit from the plaintiff's services, recovery was nonetheless allowed.
The rationale of the Kearns holding was this:
The recovery of the reasonable value of services performed, without regard to actual benefit, should be allowed "where the parties have attempted to make a contract which is void because its terms are too indefinite, but where one party has, in good faith, and believing that a valid contract existed, performed part of the services which he had promised in reliance upon it." (Kearns, 139 A. at 698).