Campbell v. Tennessee Valley Authority
United States Court of Appeals for the Fifth Circuit
421 F.2d 293 (5th Cir. 1969)
TVA library director Earl Daniel, lacking authority to bind TVA (defendant), contracted with Raymond Campbell (plaintiff) to microfilm 13 sets of technical journals for $30,240; Campbell delivered the microfilm and destroyed the original journals per Daniel's instructions, and the microfilm sat on library shelves available to patrons for two months before TVA's superiors discovered the unauthorized contract, disavowed it, and returned the microfilm while refusing payment and forbidding its use. Campbell's breach-of-contract claim failed on summary judgment because Daniel lacked authority to bind TVA, but he amended to claim quantum meruit; the jury, instructed to use the microfilm's fair market value as the measure of damages, awarded Campbell the full $30,240, and TVA appealed, arguing damages should instead reflect TVA's actual benefit or unjust enrichment.
Whether a quantum meruit plaintiff may recover the reasonable fair market value of services provided when the defendant's actual unjust enrichment or benefit received is too difficult to precisely quantify.