Disallowance of Claim for Unauthorized Services

The Naval Facilities Engineering Command requested a decision on a doubtful question of law regarding a claimant seeking payment, on a quantum meruit basis, for janitorial services performed at a Naval base prior to default termination of his contract. There was no evidence in the record of any express contract with the claimant, and all payments earned under the original contract had been validly assigned to another company. Generally, the existence of a valid express contract for services precludes recovery under an implied contract covering the same subject matter. Also, payment for unauthorized services on a quantum meruit basis may not be allowed in the absence of ratification by responsible government officials. The claim was denied.