Quantum Meruit Maryland
Quantum meruit, translated literally from Latin, means, "as much as he has deserved." BLACK'S LAW DICTIONARY, 1255 (7th ed. 1999).
The count of quantum meruit was historically used to recover "for work and labor done." Alternatives Unlimited, Inc. v. New Baltimore City Bd. of Sch. Commr's, 155 Md. App. 415, 843 A.2d 252, 286 (Md. Ct. Spec. App. 2004) (quoting 1 GEORGE E. PALMER, LAW OF RESTITUTION 7 (1978)).
In Alternatives Unlimited, 155 Md. App. 415, 843 A.2d 252 (Md. Ct. App. 2004), the court explained the historical confusion regarding Quantum meruit, stating:
Although the paths of quantum meruit and unjust enrichment have, for at least a century, diverged, they do share a long common ancestry. Some discussions, indeed, still use the terms interchangeably. Some carefully distinguish them. Some do both in successive paragraphs or even successive sentences without seeming to be aware of the slightest inconsistency. It is a field fraught with hidden pitfalls. Saul Levmore, "Explaining Restitution," 71 Vir. L. Rev. 65, 66-67 (1985), refers to it as "the remarkably uneven terrain of restitution law." (Alternatives Unlimited Inc, 843 A.2d at 284.)