Yes. GECC has to pay because it wasn't just a bystander. Usually, you can only sue the person you made a deal with. But here, GECC owned the plane that got upgraded, encouraged Midcoast to do the work, and then used its power over the money to block the payment. It's not fair for GECC to get a free fancy jet interior this way. However, the first trial might have awarded the wrong amount of money. The case needs a new trial, but only to figure out the right amount GECC should pay.

No, the whole case needs to be re-tried from the start. The first jury wasn't properly told about GECC's argument. GECC claimed Midcoast did the work for free as a gamble to try and win a much bigger contract, not because it expected GECC to pay. The judge thinks the jury should have been specifically asked to decide if this was just a business risk that Midcoast lost. Because the instructions weren't clear, the entire trial was unfair to GECC.

Yes, GECC should pay Midcoast for the work they did. The jury was right to say that it's unfair for GECC to keep the benefits of Midcoast's work without paying for it. GECC knew about the work and even encouraged it, so it's not right for them to refuse to pay now. However, the jury wasn't told the right way to figure out how much GECC should pay. They should have been told to consider either how much the work cost Midcoast or how much GECC benefited from it, whichever is less. So, while GECC does have to pay, we need to have another trial to figure out exactly how much.

I agree that we need a new trial to figure out how much GECC should pay. But I also think we need a new trial to decide if GECC should pay at all. The jury wasn't told about an important idea: sometimes, if someone does work without being asked, just to try to get more business, they might not deserve to be paid. The jury should have been told to think about whether GECC would have wanted the work if they knew they'd have to pay for it. Because the jury wasn't told about this, they might not have considered all the important facts when making their decision.

Yes. A company has a valid claim for quantum meruit against a benefiting third party when that party's conduct goes beyond mere passive receipt of a benefit and actively entices the company to perform the work. The general rule that a subcontractor cannot recover from an owner when the general contractor defaults does not apply here. GECC was not a mere passive beneficiary; it gave Midcoast assurances, emphasized the need for timely completion, and controlled AAI's finances, ultimately using that control to deny payment. These circumstances created a reasonable expectation of payment and made GECC's retention of the benefit unjust. However, the trial court's jury instruction on damages was erroneous because it measured damages by the reasonable value of Midcoast's services rather than the value of the benefit conferred upon GECC. The proper measure is the lesser of the two, and therefore a new trial is required on the issue of damages alone.

No, the jury's finding of liability should not be upheld. A new trial is required on both liability and damages because the jury instructions were inadequate. GECC's defense theory was that Midcoast provided the services 'officiously or gratuitously' as a business gamble to win a long-term contract, not with the expectation of a fee from GECC. The trial court should have specifically instructed the jury on this defense, requiring it to determine if GECC had 'knowingly and voluntarily' accepted a benefit for which payment was expected. By failing to give this instruction, the court did not adequately present GECC's theory of the case to the jury, necessitating a new trial on liability.

Yes. Midcoast presented a legally sufficient case to recover quantum meruit. The jury reasonably found that GECC's retention of benefits without compensation was unjust, violating principles of equity and good conscience. I affirm the district court's denial of GECC's motions for directed verdict and j.n.o.v. on the issue of liability. The evidence supports that Midcoast conferred a benefit on GECC by improving its plane and enhancing the Fanstar project's prospects, which GECC financed. GECC's knowledge of and involvement in the work, including providing assurances of financing, make its retention of these benefits without payment potentially unjust. Contrary to GECC's arguments, Midcoast's claim is not barred by the existence of a contract with AAI, nor by Midcoast's failure to file a mechanic's lien. However, I find that the jury instruction on damages was erroneous. The proper measure of quantum meruit recovery is the lower of either the economic cost to the plaintiff of providing the benefit or the economic enrichment of the defendant in receiving it. Therefore, I reverse and remand for a new trial on damages only.

I concur with the need for a new trial on damages but dissent on the failure to require a new trial on liability. The jury was not adequately instructed on the defense that the services might have been provided officiously and gratuitously, which could negate the requirement for compensation. When this defense is presented, the jury should determine whether the recipient would have accepted the benefit had they been aware of the provider's action. The jury instruction should have included that the benefits must not have been bestowed officiously and gratuitously and must have been accepted knowingly and voluntarily. This omission substantially misled the jury regarding the defendant's theory of the case.

Midcoast Aviation, Inc. v. General Electric Credit Corp.

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