Thurston, Appellant v. Cedric Sanders Company, Respondents

Summary

The South Dakota Supreme Court affirmed the trial court's dismissal of a quantum meruit action, holding that the complaint failed to state a claim because the underlying contract, though void for statutory non‑compliance, precluded any implied‑in‑law contract claim. The Court reasoned that a void contract creates no enforceable rights and that where a valid express contract exists, recovery on quantum meruit is unavailable.