Claim for Work Performed Without Proper Authorization by Subcontractor

The Forest Service requested an advance decision on a subcontractor's claim for work performed without proper authorization. The claimant rocked a section of a Forest Service road at the direction of an agent whom the Forest Service stated was not authorized to order the work. However, the Forest Service further stated that the road section was planned for later reconstruction and suggested payment for the work at a fair rate. In appropriate circumstances payment may be made for services rendered on a quantum meruit basis if it is shown that the government has received a benefit, and that the unauthorized action has been expressly or implicitly ratified by authorized contracting officials of the government. Since these requisites were met in the instant case, payment was allowed.