Maglica v. Maglica
California Court of Appeals
66 Cal. App. 4th 442 (1998)
Claire Halasz (plaintiff) began living with Anthony Maglica (defendant) in 1971, holding themselves out as married and changing her surname to Maglica while helping build his machine-shop business, which he incorporated in 1974 solely in his own name; after Halasz developed a successful flashlight in 1978 that made the business worth hundreds of millions, she learned in 1992 that Maglica planned to transfer stock to his children rather than her and sued for breach of contract and quantum meruit. The trial court instructed the jury it could measure quantum meruit recovery by either the cost of comparable services or the benefit Maglica received, and separately instructed the jury not to consider the couple's cohabitation and holding-out-as-married in assessing whether an implied-in-fact contract to share business ownership existed; the jury awarded Halasz $84 million, and both parties appealed different aspects of the instructions.
Whether quantum meruit allows recovery for the value of beneficial services, not the value by which someone benefits from those services.