Quantum Meruit and Future Contract Conundrum
Giant Resources, LP v. Lonestar Resources, Inc., No. 02-21-00349-CV, 2022 WL 2840265 (Tex. App.—Fort Worth June 21, 2022, no pet.). Quantum Meruit Claim.
In Giant Resources, LP v. Lonestar Resources, Inc., the Texas Court of Appeals for Fort Worth held that Giant Resources (“Giant”) is not entitled to recover under a quantum meruit claim when the claim is based on services provided in anticipation of obtaining a future contract. That is, no recovery can be had for preliminary services performed to obtain a hoped-for future contract. The court’s holding here is consistent with other Texas courts.