## Facts

- Hiram Ricker & Sons owned a large resort complex in Poland Springs, Maine.
- Students International Meditation Society (SIMS) arranged to use resort facilities from June 28 to July 26, 1970, for a course training transcendental meditation instructors.
- Ricker agreed to provide rooms, facilities, and three vegetarian meals plus a daily snack for participants.
- SIMS agreed to pay under a rate schedule tied to the number of attendees, and SIMS controlled the headcount used to calculate the bill.
- SIMS made payments totaling $185,000 before and during the course.
- After the course, Ricker alleged SIMS underpaid by understating attendance and by reducing agreed room rates.
- SIMS disputed the underpayment claim and counterclaimed for return of the $185,000, asserting the rooms and dining facilities were dirty and inadequate.
- SIMS also asserted Ricker lacked required Maine lodging and food-service licenses, arguing this barred Ricker’s recovery on the contract and in quantum meruit.

## Issues

1. Whether the evidence and the jury’s special-interrogatory findings sufficiently supported a verdict that SIMS owed additional amounts under the contract (and, alternatively, in quantum meruit).
2. Whether alleged noncompliance with Maine licensing statutes rendered the agreement unenforceable or otherwise barred Ricker’s recovery on contract or restitution theories.

## Decision

- The First Circuit affirmed the judgment for Ricker.
- The court held there was substantial evidence supporting the jury’s findings on attendance, pricing, and performance, and the interrogatory answers were not fatally inconsistent.
- The court rejected the licensing/illegality defense, concluding Maine’s licensing statutes imposed penalties but did not, absent clear legislative direction, void contracts or bar civil recovery.
- Accordingly, Ricker was not precluded from recovering amounts due under the agreement (and was not barred from restitution as an alternative theory).

## Legal Principles

- On appellate review of a jury verdict, evidence is viewed in the light most favorable to the verdict and upheld if supported by substantial evidence.
- Under Maine law, violation of a licensing statute does not automatically make a related contract unenforceable; courts look for express statutory language or clear legislative intent requiring forfeiture of civil remedies.
- When a statute provides penal sanctions for noncompliance and is silent on contract enforceability, courts are reluctant to imply the additional sanction of denying contractual or restitutionary recovery.
- Even where illegality is asserted, restitution may remain available absent an explicit statutory prohibition, particularly when total forfeiture would be disproportionate to the statutory scheme.

## Conclusion

The First Circuit upheld a jury award requiring SIMS to pay additional sums for resort services, and it held that alleged failures to obtain Maine lodging or food-service licenses did not, without clear statutory direction, invalidate the agreement or bar recovery in contract or quantum meruit.


Hiram Ricker & Sons v. Students Int’l Meditation Soc’y, 501 F.2d 550 (1st Cir. 1974)