Background
Scott Ritchie and Stephen Lieber entered an unwritten business arrangement in 2018. Ritchie Group received office space in a hangar owned by Lieber Spirit in exchange for helping Air Sansone buy, sell, and lease aircraft. Ritchie Group also made improvements to the hangar. As the relationship evolved, the parties orally discussed commissions, compensation for improvements, and rent, but disputes arose over what they had agreed to and what remained unpaid.
After the relationship ended, Ritchie Group and Air Sansone brought claims that were consolidated for a jury trial. The jury awarded Ritchie Group $975,000 in quantum meruit damages for services and awarded Air Sansone $100,000 on its breach-of-contract claim for unpaid rent. Both sides appealed after their post-trial motions were denied.
The Court’s Holding
The Court of Appeals reversed Ritchie Group’s quantum meruit award because the verdict-directing instruction was erroneous and prejudicial. The instruction departed from the applicable Missouri Approved Instruction, omitted a necessary conjunction, repeatedly used “and/or,” combined multiple possible services, included alternatives unsupported by substantial evidence, and used undefined and overly broad terms. Because it did not identify the specific compensable services, it gave the jury an impermissible roving commission.
The court also reversed Air Sansone’s $100,000 rent award because Air Sansone failed to present substantial evidence of the reasonable rental value of the portion of the hangar that Ritchie Group occupied. Lieber testified only to the annual operating cost of the entire hangar and did not connect those costs to rental value. The court therefore reversed the entire judgment and remanded Ritchie Group’s quantum meruit claim for retrial, while reversing Air Sansone’s rent claim for insufficient proof of damages.
Key Takeaways
- A quantum meruit verdict director must clearly and specifically identify the goods or services for which compensation is sought.
- Departures from Missouri Approved Instructions, including ambiguous “and/or” alternatives and unsupported theories, may constitute prejudicial reversible error.
- A party seeking unpaid rent must present evidence establishing the reasonable rental value of the occupied property; operating costs alone do not supply that proof.
Why It Matters
The decision underscores the importance of precise verdict-directing instructions, particularly when a quantum meruit claim encompasses several categories of work and some services may already have been compensated. An instruction must give jurors a factually supported and legally limited basis for determining liability.
It also shows that even when a jury finds an agreement to pay rent, a damages award cannot rest on speculation. Parties must connect competent valuation evidence to the particular space and use at issue.