Entitlement to Payment for Unauthorized Purchase

The Department of Agriculture requested a decision as to whether a company was entitled to payment for rock and gravel delivered to a job site. A district ranger ordered the delivery because he felt that there was an urgent need for it and the project coordinator, who had determined the company to be the only satisfactory supplier, had been transferred to another district before the rock and gravel was ordered. However, the ranger lacked the procurement authority to make the purchase and no formal purchase order was issued. It was held that since the goods were rendered on a quantum valebat basis, the Government received a benefit, and since the unauthorized action was ratified by authorized contracting officials, the payment was allowable.